Memo to M E Gates, Subject: Enewetak Radiological Support Project

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Department of Energy Nevada Operations Office Over the past few months we have had several conversationsregartig the role of the IDE Enewetak Project Manager. Of specific concern to me at this time is the role of the Project Manager as a participant in the DNA decision-m~g process. My concern has become acute because of two recent occurrences: 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 in the 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. I kIIOW that this scenario is at variance with what someothers both in DNA and in our Headquarters expect; but it is the product of almost S5X years of study of, and experience with, ihe Enewetak siti~ation,and 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 rneand to express his disagreement. Yet I believe that you will fti.dunanimous agreement with the concept here-k descriloed, by these seven senior people (ticluding myself) who are closest to the issue and who each must individually represent the Department of Energy Let me first review a few of the “givens” in the cleanup progra. 13rst, by its very nature, the scope and magnitude of the program are ill-defined, and will remain so until we are well into the actual implementation. Ii was for this reason that I suggested in 1972 that —

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at least iiiitiallyit might be more reasonable to authorize a “level of effort” program rather than to try to define and design and schedule as one might in a more conventional engineering job. Second, and perhaps the most important given, is the fact (and it is fact) that there is no way that Mewetak can be restored radiolog~ally to the Atoll that it once was. With the limited resources that have been made . available, there will of necessity be tasks left undone and conditions left unimproved. Many compromises with desired standards will be required, many trade–offs will be examined. Third, and finally, overall responsibility for the cleanup of Eneweta!!has been squarely placed upon the Director, DNA. His must be the decisions, and it is he who must answer to the Congress for the rationale of aecision, the stewardship of resources, red-of course, the end product—the condition of Enewetak when the project is complete. Our role, as I have repeatedly said to both the Director DNA and the Commander, Field Command, is to assist the responsible agent of the Director (the Commander of the Joint Task Group) in assessing the radiological component of his decisions, Note that the ciecisionswhich this paper addresses nave to do exclusively with the removal of soil which is contaminated with At this time we have only a gross picture of the surface concentrations for most of the islands of ~Eneweia!k.We are acquiring more detailed information, island ‘oyisland; ar.dDlL4hopes, in the very near future, to commence soil removal. The guidance for soil removal provided by the AEC in 1974, is admittedly just that--general guidance. It recommends soil removal wherever a concentration of 400 pCi/gm or greater is found; it accepts concentrationsbelow 40 pCi/gm as requiring no action; and it provides for a “case-by-case”determination in the range between 40 and QX2. It is really this case–by-case determination which becomes the issue. for the DNA command authorities have chosen to consider the “abcve 400” criterion as direction rather than guidance; and, thus, the removai of all soil exceeding that criterior.as the sine-qua-nonof a successful cleanup. Many (perhaps most) of the informed D3E observers have disagreed with such a literal application of the guidance; but again, Eirector, DNA, has the mandate and the . “.When one looks at the portion of the task which the Commander, Field Command, chooses to term “discretionary’’--thatis, soil removal in the 40-~00 range–-it is apparent that it will be a major consumer of resources and till likely have the greatest impact upon resettlement options. It is generalUJ accepted that (other conditions being equal) the potential usefulness of an island will be in inverse proportion to the average concentration of transuranicsremaining after cleanup. Thus, an island which has been brought to below 40 pCi/gm may be

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considered acceptable for permanent residence; one which is below may have limited usefulness. But other conditions are not equal. As we have seen at Bikini, the distribution of land rights and cultural considerations, among other things, are in conflict with the purely radiological considerations. And at Enewetak, Engebi--if it had no transuranics in the soil--would likely be relegated for sometime to limited use. Yet it is very important to the identity and well-being of the Engebi people. Size, configuration, approaches, orientation to wind and spray-these are some of the other factors to be considered. Most of all, with limited resources, the Task Group Corrmandershould consider the Atoll as a whole. “Case-by-case” consideration of the resources to be applied to one island must include consideration of what else might be done with those same resources applied elsewhere. And so, the people of Enewetak must, in some way, participate in that deliberation. The ‘i’askGroup Commander will never have accurately quantify all of the sub-tasks considerablepressure to start using, to forces that have been provided him. And has sufficient information upon which to enough information to in advance. Eut he is under the fullest, the cleanup only he can decide when he act. If I were in that role, I should try at the e~liest possible date to develop two ordered lists of islands. The first would order them as to the relative amount of effort required to bring each to its desired condition (more than”one condition might be considered for some islands). The second ordering would be with’respect to the potential value or usefuhess of an island. With these two lists in 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 ressed as a level of soil contamination (or matimum concentration which will remain in a given area after cleanup action is complete. We should anticipate that he may change h5s objective to a higher or a lower number as the scope.unfolds. basically three ways: He will furnish a detailed radiological description of the area o; island being considered; he will pro~de to the - Commander, and continuously update, an estimate of the quantity of material to be removed in order to meet a given objective; and he will assist the representative of the people of Enewetak to understand the need for, and the significance of, their participation. .

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Much has been said, but too few words have been written about Certification. With your concurrence, I wrote Jim Iiveeinanon November 11, 1977,proposing a format for Certification. I have not had a response to that letter, but I am aware that it is under considerationby OES. I have not changed my tiew that the Certificationprotided by the Project Manager should be documentation of the conditionin which each island is left, rather than a ,judgementas to whetlnerthat was the appropriate thing for the Defense Department to do. Any such judgement would necessarily contemplate the entire cleanup effort, rather than each individual island as a separate entity. Yet DNA insisted upon, Shedd MOUof September 1975). Someone at some level in one of our departments must have the authority to make the day-to-day cleanup decisions. In my view, that is clearly the Task Group Commander. The LX)EProject Staff is a part of his Task Groun and is committed to assisting the Commander with advice and technical support. V/ehave devoted a great deal of energy over the past few years to helping DMA to interpret the AEC guidance for cleanup. If a judgement is now to be made as to 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 with his. Nor will we hesitate to notify you of differences which we carmot resolve. But until otherwise instructed and empowered, I intend that our project,role continue to