Letter to M E Gates, Subject: Enewetak Radiological Support Project.

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Department of Energy Nevada Operations Office ENEWETAK RADIOLOGICAL SUPPORT PROJECT Over the past few months we have had several conversations regarding the role of the DOE Enewetak Project Manager. t o me at this time is the role of the Project Manager as a participant in t h e DNA decision-mal.;ing process. because of two recent occurrences: Of specific concern My concern has become acute 1. Our early November discussion with Hal Hollister, wherein he expressed disagreement with my philosophy of participation. 2. A recent request received by John Stewart (currently acting for me as Deputy Project Manager on site)that he concur inthe establishment of the detailed cleanup objective for one of the Northern islands, Lujor. In this paper I describe what I visualize as the appropriate mechanism and sequence of decision and the DOE Project Manager's role. that this scenario is at variance with what some others both i n DNA. and our Headquarters expect; but it isthe product of almost six years of study of, and experience xith,the Enewetak si.tuztiicn, acd of many tens of hours of argument, debate, and soul searching. I believe that each of my six Project Management Deputies feels completely free to disagree with me and t o express his disagreement. Yet I be1ie;re that you will find unsnhous agreement with the concept here in described, by these seven senio? people (including myself) who are doses t to the issue and who each must individually represent the Department of Energy during rotational on-site tours. Let me first review a few of the " given s " ' hthe cleanup program. First, by its very nature,the scope and magnitude of the program are ill - defined, and will remain so until we are tiell into the actual implementation. It was for this reason thatI suggested in 1972 that

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atleast ih ti ally it might be more reasonable to authorize a ',level of effort " program rather than to try to define and design and schedule as one might i n a more conventional engineering job. perhaps the most important given, is the fact (and it is fact)that there is no way that Enewetak can be restored radio logically to the Atoll that it once was. available,there will of necessity be tasks left undone and conditions required, many trade-offs will be examined. responsibility for the cleanup o f Enewetak has been squarely placed upon the Director, DNA. His must be the decisions, and it i s he who must answer tothe Congress for the rationale of decision,the stewardskip o f resources, and of course, the end product-the condition of Enewetak when the project is complete. said t o both the Director DNA and the Commander, Field Command, isto assist the responsible agent of the Director (the Commander of the Joint Task Group) in assessing the radiological component o f his t o do exclusively with the removal of soil which i s contaminateti with With the limited resources that have been made Many compromises with desired standards Will be Our role, as I have repeatedly Note that the decisions which this paper addresses have A t this time w e have only a gross picture of the surface concentrations for most of the island sol Enewetak. information, island by island ; and DNA hopes, inthe very near future,. t o commence soil removal. the AEC i n 1974, i s admittedly just that--general guidance. It recommends soil removal wherever a concentration o f 400 pCi/gm o r greater i s found; it accepts concentrations below 40 pCi/gm as requiring no action ; and it provides fora "case-by-case" determination inthe range between 40 and 400. It is really this case-by-case determination which becomes the issue,for the DNA command authorities have chosen t o consider the "above 400fr criterion as direction rather than guidance; and, thus,the removal of all soil exceeding that criterion as the sine-qua-non of a successful cleanup. informed DOE observers have disagreed with such a literal application of the guidance; but again, Director, DNA, has the mandate and the When one looks at the portion of the task which the Commander, Field Command, chooses t o term "discretionary"--that is, soil removal i n the 40-400 range--it i s apparent that it will be a major consumer of resources and will liE ely have the greatest impact upon resettlement options. It is generally accepted that(other conditions being equal) the potential usefulness of an island will be in inverse proportion t o the average concentration of transuranic s remaining after cleanup. Thus, an island which has been brought t o below 40 pCi/gm may be We are acquiring more detailed The guidance for soil removal provided by Many (perhaps most) of t h e

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considered acceptable for permanent residence; one which i s below 100 pCi/gm may be intensively farmed; and one which exceeds 100 pCi/gm may have limited usefulness. But other conditions are not equal. distribution of land rights and cultural considerations, among other things, are in conflict with the purely radiological considerations. And a t Ehewetak, Engebi--if it had no transuranic s in the soil--would likely be relegated for sometime to limited use. important to the identity and well-being of the Ehgebi people. Size, configuration, approaches, orientation to wind and spray--these are some of the other factors to be considered. resources,the Task Group Commander should consider the Atoll as a - whole. "Case-by-caseqq consideration of the resources t o be applied t o one island must include consideration of what else might be done with those same resources applied elsewhere. And so, the people of Ehewetak must, i n some way, participate in that deliberation. As we have seen a t Bikini, the Yet it i s very Most of all, with limited i The Task Group Commander will never have enough information t o accurately quantify all of the sub-tasks i n advance. considerable pressure to start using, to the fullest,the cleanup forces that have been provided him. Ar,d only he can decide when he has sufficient information upon which toact. role,I should try at the earliest possible date to develop two ordered lists of islands. The first would order them as tothe relative mount of effort required to bring each to its desired condition (more than one condition might be coxxidered for some value or usefulness of an island. With these two lists i n hand, a first approximation of the distribution of effort should be developed. Both lists, and therefore planned distribution of effort,will change as more and more information becomes available ; and so the Task Group Commander's detailed cleanup objectives should be considered flexible. Each objective will be e .(or maximum concentration7which will remain ina given area a it er cleanup action is complete. his objective to a higher ora lower number as the scope-unfolds. But he i s under If I were in that The second ordering would be with respect to the potential res sed as a level of soil contamination We should anticipate that he may change basically three ways: tion of the area or island being considered; he will provide tothe Commander, and. continubusly update, an estimate of the quantity of material t o be removed i n order t o meet a given objective ; and he will assist the representative of the people of Ehewetak t o understand the need for, and the significance of,their participation. He will furnish a detailed radiological descri.p-

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Much has been said, but too few words have been written a but Cert i - 1977, proposing a format for Certification. to that letter, but I am aware that it i s under consideration by OES. I have not changed my view that the Certification provided by the Project Manager should be documentation of the condition i n which each island is left,rather than a judgement as t o whether that was the appropriate thing for the Defense Department t o do. would necessarily contemplate the entire cleanup effort,rather than each individual island as a separate entity. Yet DNA insisted upon, Shedd MOU of September i975). Someone a t some level in one of our departments must have the authority to make the day-to-day cleanup ' The DOE Project Staff is apart of his Task Group and i s committed to assisting the Commander with advice and technical support. devoted a great deal of en erg j over the past few years to helping D M to interpret the AEC guidance for cleanup. be made as t o whether DNA has adequately followed the guidance, I believe that that judgement should come from some independent appraiser or from the authors of the guidance themselves. Permit me one final point. Be assured that neither I nor any of my deputies will hesitate to argue with the Task Group Commander if we have views that are at variance w5th his. notify you of differences which we cannot resolve. instructed and empowered, Ii ntz nd that our project role continue t o With your concurrence, I wrote J i m Liverman on November 11, I have not had a response Any such judgement In my view, that is clearly the Task Group Commander. If a judgement i s now t o Nor will we hesitate to But until otherwise