Memo, Subject: This Will Tidy Up the Paper Work on the Meeting Last Week in Las Vegas (Attch: Letter to J L Liverman, Subject: Plans for the Cleanup of Enewetak Atoll Were Reviewed)

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‘ This will tidy up the paper work on the meeting last week in Las Vegas. Thanks again for your participation.

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for Environment and Safety In response to your request of August 11, 1977, plans for the cleanup of Enewetak Atoll were reviewed at a meeting at the Nevada Operations Office, August 15-17, 1977. A list of participants in the review is Prior to the meeting, the reviewers were provided copies of documents relative to the development of cleanup criteria antipreparation of the EIS. Supplementing these were briefings by Joe Deal, Tommy HcCraw, Roger Ray, and members of the Staff of the Defense Nuclear Agency. Mr. Stevens reviewed the Environmental Impact Statement and Major General Shedd and Colonel Hemler described operational plans for soil cleanup and crater disposal. In addition, Mr. M. Gates, Manager of the Nevada Operations Office, met with the re~ewers discuss~d points he raised-in his letter to you. retiewers addressed two primary issues: The criteria for cleanup of the islands contaminated with The plan for disposal of plutonium contaminated soil and other radioactivity contaminated debris in the Cactus Crater. Several other related issues were addressed during the discussion. Summary of the Reviewers’ conclusions There was unanimous agreemeut that the criteria for cleanup of the islands contaminated with plutonium are reasonable in the light of present knowledge and their application does not pose an unacceptable health risk.

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Although the reviewers identified alternatives that may be preferable, there was unanimous agreement that the planned emplacement of plutonium contaminated soil and debris in concrete in the Cactus Crater does not impose unacceptable environmental and health risks. Review of Plans for Cleanup,.of Enewetak Atoll A, Criteria for removal of contaminated soil The reviewers considered the criteria for the relocation of approximately 10 Cl of plutonium from dispersed locations in the terrestrial environment to a central location in the Cactus Crater on Runit Island. value adopted in the Environmental Impact Statement a8 a minimal action level and with 400 pCi/g as the mandatory cleanup level. Using the assumptions in the EIS the reviewers estimated that the lung dose resulting from lifetime inhalation of air containing an equivalent concentration (100 Bg soil/m3 air or or 1 mrad/year, assuming a quality factor of 16. This compares with the proposed EPA federal guidance value of 1 mrad/year to the lung from transuranic elements in the environment. The reviewers believe that lung doses from inhaled plutonium will be considerably less than this for persons living and working on the Atoll because of the small land area which minimizes buildup of plutonium concentrations in the air and because of the conservative assumptions used in estimating dose; e.g., all contaminated soil was considered respirable, the concentration of soil in air was maintained constantly at the 100 vg/m3 level, etc. The reviewers reconmend that more specific guidance for application of the criteria at plutonium levels between 40 and 400 pCi/g be developed for the Task

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The Environmental Impact Statement indicates that is the major problem which will limit the occupancy and utilization of certain islands of the Atoll. Certain soil amendments that have been shown to significantly decrease the uptake of these radionuclides may be useful for hastening the rehabilitation of the Atoll. B. Disposal of plutoni-contaminated soil and debris in the Cactus Crater In examining the question of disposal of contaminated soil and debris, the reviewers considered potential human health effects, future maintenance and monitoring requirements, retrievability, potential restrictions on access to Runit Island, implications and risk of reopening the Environmental Impact Statement, costs, quantities of debris, and engineering problems. Weighed against these considerations the reviewers agreed that the planned emplacement of concreteencased plutonium-contaminated soil and debris in the Cactus Crater would not in itself impose unacceptable human health risks. me IrI12thOd cculd result in the gradual release of this plutonium to the marine environment; this would be in addition to the 1500 Ci already in the lagoon sediment. Bowever, for the worst case in which 10 Ci Pu is added to the Crater below the water level, the local lagoon water plutonium concentration would not fncrease more than by a factor of two. This could lead to an increased dose of a few mrem per year to a person who obtained all of his food from the local marine environment. Several alternate disposal schemes, while not significantly influencing the health risk prospects, might be preferable. While it may be inadvisable to change disposal plans at this late date, the reviewers believe you should be aware of the possible advantages of other methods.

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Ocean dumpin~~as considered to be the preferred solution by most of the reviewers. While the. quantities-of soil and debris are high (75,000225,000 yds3), the plutonium inventory is estimated to be only in the order of 20 Ci, an insignificant smount to dump into the Pacific Ocean compared to that which is already present in the ocean from weapons test fallout. Presently 3-4 Cl is transported from the waters of the lagoon to the open ocean each year. We understand that EPA interprets PL 92-532 to effectively prohibit ocean dumping by the U.S. H&ever, the U.S. has contributed technical guidance and is signatory to the international agreement on the dumping of radionuclides in the ocean under the London Convention which “allows” dumping of much larger quantities than 20 Ci of plutonium. Advantages of deep ocean dumping include the removal of the plutonium completely from the Atoll environment and the elimination of the need for any future monitoring and maintenance. However, the EIS would probably have to be reopened and an oceanographic survey. Lagoon dumping as an acceptable aitermate ta Gceaa dumping minimizes international ramifications. Since.- soil would be slowly dispensed to the lagoon during the cleanup and only a small fraction of the bound plutonium will be remobilized, the actual impact on the lagoon water concentration till be slight. It can be demonstrated by computation that less than 0.01% of the plutonium would be remobilized to the . solution phase during disposal to the lagoon. The majority of material would settle to the floor of the lagoon. Concentrations of plutonium in aquatic organisms might increase, but since the residence time for sea water in the lagoon is about 150 days, the concentrations would shortly be reduced to smbi.entlevels. Again, the EIS would have to be reopened and permits obtained from the EPA, other Federal agencies and the Trust Territory.

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Terrestrial disposal on Runit Island with a concrete cover would have the least immediate impact on the local marine environment in that remobilization of the radionuclides from the soil to the groundwater and eventually to the lagoon is minimized. TM.s method would maximize potential occupational exposures during the cleanup operation. Terrestrial disposal by covering the existing contaminated areas on Runit with contaminated soil removed from other islands, but without concrete cover, was also considered. This would reduce the average surface levels of plutonium on Runit, but might require quarantine. Both terrestrial disposal methods would allow retrievalof the plutonium. Both would require reopening of the EIS. Other methods for disposal of plutonium,were proposed. One interesting possibility is the application of mining and milling techniques to separate plutonium from the soil of Enewetak Atoll. The reviewers were nut aware cf this having been explored. While such a technique could not be available for application to Enewetak Atoll, it might be useful at other sites in the C. Future ERDA Commitments at Enewetak Atoll According to the Environmental Impact Statement, ERDA is committed to long-term monitoring che the Enewetak Atoll. Planning for this responsibility appears to be incomplete. The reviewers offer the following suggestions: 1. The environmental monitoring program should be as inconspicuous as possible and should be aimed at estimating radiation doses to the inhabitants of 2. Any activities carried out by individuals other than the Enewetakese should be conducted only if it is ascertained that the activity has minimal impact on the inhabitants.

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During the next three years a study of resuspension of plutonium from soils in - circumstances typical of those that will occur when the islands are reinhabited should be conducted. It is emphasized that this should not be a study of resuspension associated with cleanup activity per se. Information applicable to the Enewetak people will be invaluable in improving estimates of radiation dose to human beings returning to the islands and will assist in reaching decisions about future use of specific islands. The EPA regards the crater disposal method as temporary storage. Under this view, maintenance of the concrete structure may be required. The Defense Nuclear Agency r,egardsthis method as permanent disposal which would imply no maintenance. This could lead to uncertainties of responsibility for future activities at the crater site. A programmatic effort must be initiated to communicate to the Enewetak people the nature of the risks to which they will be exposed. The potential risks associated with living and visiting the various islands -t be made comprehensible to the people from their perspective to Insure their understanding the need for restricted access to Runit, etc. D. Concern for incomplete cleanup The reviewers were concerned that the cleanup program, as defined in the EIS, could be terminated before completion if the funds and other resources - appropriated for the effort proved to be insufficient due to underestimates of the magnitude of the amount of soil that has to be removed.

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b conclusionit shouldbe emphasizedthat only the adequaw of the cfiteriaand disposal methods were reviewed and that the operation~ @Lans for assuringimplementationsof the criteria were not examined

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Assistant Manager for Environment and Safety Nevada Operations Office U. S. Energy Research and Development Administration Armed Forces RadiobiologyResearch Institute

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REVIEW OF ENEWETAK CLEAN-UP CRITERIA AND DISPOSAL NEVADA OPERATIONS OFFICE Manager, Biomedical and Environmental Programs Sotl Scientist, Environmental Sciences Division Oak Ridge National Laboratory Director, Health and Safety Laboratory U.S. Energy Research and Development Administration Los Alamos Scientific Laboratory Director, Inhalation Toxicology Research Institute Lovelace Foundation for Medical Education and Research Section Leader for Marine Sciences, Environmental Sciences Division Lawrence Livermore Laboratory Senior Staff Scientist, Biology Department Battel.leHuman Affairs Research Center, Seattle

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Deputy Director, Division of Biomedical and Environmental Research U.S. Energy Research and Development Administration Assistant Director for Field Operations Division of Operational and Environmental Safety U.S. Energy Research and Development Administration Division of Operational and Environmental Safety U.S. Energy Research and Development Administration Assistant Manager for Environment and Safety Nevada Operations Office ,U.S. Energy Research and Development Administration Research Program Coordinator Armed Forces Radiobiology Research Institute Defense Nuclear Agency Office of the Assistant Administrator for Environment and Safety U.S. Energy Research and Development Administration

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Guests - Defense Nuclear Agency Major General William E. Shedd, USA Deputy Director for Operations and Administration Brig. General Grayson D. Tate, USA Commander, Field Corrrnand F Col. John Hemler, USA Director of Operations, Field Command Lt. Col. Manuel Sanches, USA Logistics Directorate, Field Command Logistics Directorate, Field Command Logistics Directorate, Headquarters

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Background - Joe Deal Operational Viewpoint - Roger Ray Defense Nuclear Agency Introduction - Maj. Gen. Shedd - Review of Crater Containment Operations and Disposal Flans - Closing Remarks - Maj. Gen. Shedd Tuesday - Friday, August 16-19 Activities of the Review Committee - William J. Bair

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ENERGY RESEARCH AND DEVELOPMENT ADMINISTRATION Manager, Biomedical and / Environmental Research Program Pacific Northwest Laboratory This will confirm recent telephone conversations seeking your assistance in the review of the cleanup criteria for Enewetak that AEC/ERDA was responsible for preparing. The key element in plans for the ongoing Enewetak Atoll project is recommendations for cleanup and rehabilitation criteria developed by an AEC Task Group in June 1974, and decisions by Defense Nuclear Agency (DNA) on crater disposal of contaminated debris and soil on Runit Island. Several factors opt for a final review of these recommendations and decisions; namely, EPA has in draft for final review, “Guidance on Dose Limits for the Transuranium Elements in dicated his professional staff have voiced objections to the disposal plan and believe that “soil cleanup” of the northern islands according to AEC guidance is unsupportable, unsound, and counterproductive;concern has been expressed for the cleanup guidelines in a letter to Dr. Liverman which was prepared by a number of scientists at the time of the Livermore review of all AE5 Pacific activities on June 27-29, 1972; 000 hd~ a heavy cotrunitmentto the cleanup of Enewetak Atoll and to a technique of disposal that has changed with time and will shortly begin to expend considerable effort in soil removal and disposal activities; and ERDA has commitments to provide certification of Enewetak cleanup and long term radiological followup of the Atoll when it is resettled. You are invited to participate in a review of: 1. AEC recommendations for cleanup and rehabilitation of Enewetak Atoll and specifically the criteria for plutonium-239 in soil, and 2. Environmental and health implications and long term monitoring requirements for crater disposal of contaminated debris and soil on Runit Island.

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A copy of the AEC Task Group report is enclosed along with additional background material. You will be informed of arrangements for a review session, which is expected to be held next week at a locatlon as yet undetermined. If there are any questions, please contact Bruce Wachholz on 353-4365 for Environment and Safety

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Identical Letters Sent To: Manager, Biomedical and Environmental Research Program Pacific Northwest Laboratory Pacific Northwest Laboratory Director, Inhalation Toxicology Lovelace Foundation for Medical Education and Research Albuquerque, New Mexico 87115 Los Alamos Scientific Laboratory Los Alamos, New Mexico 87545 Director, Health and Safety Laboratory New York, New York 10014 Pacific Northwest Laboratory

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Identical Letters Sent To: University of California Lawrence Livermore Laboratory Department of Environmental Medicine New York University College of Medicine New York, New York 10016