The incremental costs for the Fission Product Data Base Program were, in thousands: Eberline - $230 - $320 H&N/PTD Total $90 These costs were incurred in FY 79 and are included in the overall ERSPtotals stated above. 2.2.3 Plutonium Versus Total Transuranics Presentation of sampling results (plowing, th4 the ot 9? 2-73 Enewetak Radiological Survey (NVO-140) usually referred to plutonium as 239 pu or 40 Pu, The AEC Task goroup est Re and the EIS followed the pattern of NVO-140 and continued to refer primarily to 239 py or 23 Opy. There was a tendency to shorten the reference to just "Pu" as may be seen in the discussion of OPLAN 600-77 presented in Appendix E. By the summer of 1977, ERDA staff members were making occasional reference to "transuranics" instead of "plutonium". Two developments in late 1977 brought the question of plutonium vs. transuranics to the forefront. The first was the release by EPA of new dose guidelines for transuranic elements in the environment. The second was discovery that 238py concentrations found in the soil of Island Pearl made a signifieant difference in the volume of soil that might have to be removed to meet the criterion anticipated for this island. DNA obtained oral assurance from EPA that the new draft guidelines, which were more stringent than earlier guides with regard to transuranics, would not apply to Enewetak, then or in the future. Nevertheless, DNA was concerned that ERDA might adopt and implement the new guidelines independently, creating a much larger requirement for soil removal than had been previously planned. Several DNA staff members attempted to independently evaluate the impact that including total transuranics would have on soil removal volumes. A mathematical/statistical approach indicated the potential volume could increase from about 87,000 ya3 to about 147,000 yas, excluding soil cleanup from Yvonne, and assuming cleanup of all soil indicated to bear total transuranic concentrations greater than 40 pCi/g of soil. (Bramlitt, 12/1977.) Another study compared the response, in terms of soil volume, to changing the intended use of selected islands as compared to including 2 38pu and 24lAam in the cleanup criteria. The conclusion of this study was that DNA should not object to inclusion of 288pu and 24!am in calculating soil contamination levels for cleanup, since the impact of inciusion would be considerably less than changing the intended use. (Treat, 12/29/1977.) Both studies utilized data reported in NVO-140, and qualified their conclusions to the effect that ongoing characterization activities could lead to different conclusions. The ERDA/HQ (DOE as of 1 October 1977) staff, although saying Pu for many years, stated that they had intended to mean transuranics all along. (McCraw, 11/1977.) From September 1977, when DNA began to develop concern over the transuranics question, to late December 1977, when the question had beeome acute for DNA, DOE/HQ remained silent, except to say that transuranies was always intended rather than just "Pu". (Treat, 12/8/1977; MeCraw, 12/1977.) By late December 1977, several issues requiring attention had developed. A resolution conference was held at DOE/HQ on 6 January 1978. Because DNA had already reached internal agreement not to object to expansion, in their view, to include total transuranics in the cleanup calculations, the conferees were able to report: "Consequently, the conference made a tentative agreement subject to confirmation or change, once the full scope is known, that the soil cleanup criteria would be considered to apply to all transuranic isotopes. . . Since cleanup planning was based on removal of soil contaminated with 239,240 py, this change in definition of cleanup criteria might mean the degree of cleanup of certain islands may be more or less than planned in view of the fixed level of funding." (Deal, 2/1978.) of