Memo to D Gestiehr, Subject: Gao Draft Report " Observations on the Project to Cleanup, Rehabilitate and Resettle Enewetak Atoll " (Enewetak Cleanup)

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GAO DRAFT REPORT “OBSERVATIONS ON THE PROJECT TO CLEANUP, REHABILITATE AND RESETTLE ENEWETAK ATOLL” With a deadline of December 11, 1978 fort~&~ents to EV~ four working days i.s~ not sufficient~to conduct an indepth review and to prepare comments on a report covering a subject as complex as this one. The following comments are directed at subject areas in the report where the facts as we know them either do not support statements in the GAO draft report or where our information suggests that the report is not complete. 1. Page 3 - There are at least seven phases in the Enewetak a. The initial radiological and engineering suveys and assessments conducted by DOE and DNA. ‘ C* Environmental Impact Statement (EIS) development and Project/Budget defense by DOE, DNA, and DOI. d. Cleanup field operations managed by DNA with radiological support provided by DOE. e. Rehabilitation performed by DOI with logistics support from DNA and technical support and advice provided by f. Long-term radiological followup of the environment (except for the engineered features of the CACTUS crater encryptment of contaminated debris but including monitorin~ of any effluent”from the crypt) and residents of the atoll by DOE. ~“ Long-term engineering followup of CACTUS crater debris disposal by DNA. @

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The idea of enforcement 2“ m upon Enewetak residents is foreign to AEC/~A/ DOE thinking and we have never used the term. Recommendations for restrictions on land and food u.se.atheweatak,‘ have been nade with the expectation that there will be4 4 a good level of compliance by the ~eople but 100 percent compliance may not be achieved. In fac>the thinking has been that if such restrictions required 100 percent co~pliance in order to be able to agree that the people would be adequately protected, the resettlement should not be attempted. We suggest avoiding use of the tern “enfcrcenent.” 3* Page 5 - The single nest inportant recommendation of the All Cad hoc committee was that the first houses and food crops-be placed on Eneu Islm.d3 the second largest island inktbe--a%d. Compliance with this most basic recomxndation at the insistence of the Bikini geople and 8J,COC coconut trees were planted on Bikini and Eneu Islands. 4. Page 6 - There is a better listing of similarities =d differences for Bikini and Enewetak Atolls. See EnclosUre~, Similarity should’included the statement that all isl=-ds at Differences should state that most (but not all) tests at Bikini were copducted over water. For inst=ce, shot E~J-~0 ; the larges conducted in the Pacific Proving Grolw-d, ~ was conducted on an isl.zndat l?ik”ni.Atoll. Also, a comment is needed on the DNA material.~ the isotopic conte nt of the contamination found or~ Bikini and Ihewetak. Our data indicates that isotopic ccmt.entof scrap and soils at these two Atolls is not enough different to support the point that at Bikini contamination is principally the Tresult of fallout and ~l?e%;etaiit is induced plus fallout.

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Many Enewetak tests were on steel towers. Many Bikini4 tests were on steel barges moored near shore. There is induced radioactivity plus fission products in the ~Rl~out that contaminated the islands at both Atolls. One ~~ see differences in x isotopic content of contamination between islands at Eikini and Enewetak but there are just as large differences between islands within the sane atoll. The only .~eally unique island in our view is xachunks of I% were deposit&d in suface soils in an area wh~re tests gave no nuclear yield or essentially no nuciear yield. Nothing sinilar to this has been found i Page 9 - So far as DOE is aware, there is only one development related to living pattern restrictions at Enewetak requiring any cflangein DOE recomnendaticns and this has nothing w~ to do with debris and soil cleanup and in fact nothing to do with any recent experience at Enewetak. Rather, the unacceptably high Cesium-137 ha-d-~’~~ burdens of Bikini residents and the failure of a recommended precaution against use of locally grown foods (par5n sir.ilarlycontaminated soils at Enewetak or in soils anywhere near the Bikini levels. As a result of this experience, DOE deemed it prudent to recommend that islands in the northeast at Enewetak not be planted with coconut. Another thing learned from the Bikini experience is that whenever the preferences of the Enewetak (or for that matter Bikini) people conflict with good radiation protection practice, DOE must stand by its best judgement recommendations regardless of what=~~ Master Plan or other earlier documents may state. While we support all possible inputofrom the people, radiation

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of the aborted resettlement of Bikini Atoll nay be repeated. , Many times in our interactions with DNA staff we have made the point that cleanup of Enewetak is a Project without an applicable precedent and things may be learned during the process of study and work in the Atoll that will change our recommendations. The basic radiological survey was done in 1972-73 and the AEC Task Group began its work on cleanup criteria concurrently with this survey. The basic recommendations frcm AEC were issued radiological measurements have been Dade in the atoll than djring all other surveys conbined. It is fortunate there have not been nore changes in the original AEC recommendations than this one change.WAS a matter of fact, in developing cleanup options the initial preferred option for agricultural use of Enewetak was to restrict planting of food crops to the southern islands. The earliest dose estinates were made for this otpion. When predicted doses for this option were found to be well within the radiation exposure tiriteriarecommended for cleanup and rehabilitation, and with pressure from those planning agricultural rehabilitation to allow all possible land to be planted, this option was modified to consider planting coconut trees on certain . northeastern islands. Dose estimates were recalculated and while higher than before, were still within the criteria. The final recorm.endedoption contained a revision allowing coconuts to be planted on certain northeastern islands. From the Task Group viewpoint, DOE has reverted to an earlier preferred position. The lesson is this is not to try, with so many variables,ti develop a cleanup and rehabilitation option that just fits within the criteria.

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6. Page 10 - The tiKhaxa& footnote on this page is incorrect.~ 79 Page 12 through 14 - These pages contain many errors in “ fact~and conclusions drawn are not supportable. The points requiring comment may be~warized as follows: solutions. These may require more living pattern restrictions. Subsequent adoption by DOE of a more conservative philosophy relative to soil cleanup will require that more soil be exicised and some additional islands may haved to be quarantined indefinitely due to lack of resources and tine to clean then up. Dose estimates have switched from averages to AEC Task Group,-kcrlteria have been made nore stringent Initial Task Group cleanup guidelines considered only Pu-239, 240. These were later broadened to include all Coconut intake of Enewetak peep c4TecentlY estinated to X be 10 times greater than wh$#~~~a;%s developed. The 40 and kOO picocouries per gram criteria have been made more stringent. Comments on Item a - The only development requiring a modified solution was the Bikini exp~~ience which led DOE to recommend against planting coconuts on the northeastern islands. 3?WWXE There has x been no other change in land use recommendations . ‘a iving patterns restrictions fron DOE. This item was covered Comments on Item b - DOE philosophy relative to radiological cleanup and rehabilitation of Enewetak Atoll and recommended radiological criteria for cleanup were f~ed with the issuance Of the AEC Task Group report in 1974. There has been no need for a

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change in either of these. DNA’s perception of this philosophy and these criteria has changed as their experience in the application of the cleanup criteria has broadened. AEC’S approach, and DOE has followed the same, has been to view this project as a practical problen in radiological protection, not an engineering ~. Thus, the philosophy used is the philosophy & current radiation protection ~ that arefitoguide Federal agencies in their radiation protection activities. IIOE cannot unilaterally cfiangethe philosophy GEZ@ the basis numerical standards that have been derived therefron. It has also been our practice to ~~$ ~ a factor of standardskto real-~ld prcblenl. ~hls explains why the average or most.likely value rather than worst case is used for the ~anY involved in developing dose estimates for comparison In applying Federal’Stan~ards the Task Group selected 50 percent-~ of th-eannual doses for individuals in the general public and 80 r exposures of people living in the area may reach the standard. 1 The Task Group selected 40 pCi/g or 10 percent of the ~00 PCi/g ti~ as the level below %Thichsoil cleanup would not be required. F. set this low for ciianup of ‘KEnewetak)a precedent would be set ~

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4?‘ As to the indefinite quarantine of islands,to our knowledge +?, only one island has ever been discussed in this context. This ~ is Runit Island. The AEC Task Group considered Runit a special case and made no recommendations for cleanup specific to that island. The selection of Runit for disposal of contaminated debris and soil was made by DiYAon advice from EPA. The AEC! had no part in this decision aridhad $mmzxd favored ocean disposal. Once lXA nade the decision that Runit would be a dedicatec disposal island, DOE did urge that any soil cle~-nuPof R~it be placed at the bGttom of a list of cleanup priorities. Comments on Ttem ,4 - DOE dose estinates use averages, not worst region. This item may refer to some recent dose estinates developed by DNA staff for which DOE and its contractors have provided cements. Our present intent is to continue to use Comments on Item d - DOE has not made ra~iological cleanup criteria more strir.gentbecause of the EPA proposed guidelirles. EPA staff-are quite familiar with the AEC development of cleanup criteria for Enewetak. EPA provided an observer to attend meetings of the Task Group on Recommendations. Sections of the draft were provided to EPA.for comments and suggestions Wthe roup’s report was developed. 7 EPA participated in the review process for the Enewetak EIS which was based upon the . There have been staff level discussions between EPA and DOE as work progressed on the~proposed EPA gtidance. An Important

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point to recognize is that the AEC recommendations for cleanup of plutonium in soil were derived fron basic Federal standards ~ and therefore~are re abed to dose to Dan. The criteria of radioactivity in soi>= relatable to dose. The proposed centrations are to be derived fron W dos+ using appropriate It is our view that if cleanup ~f isl.and~at Enewetak is ac,cpy~ plish d according to the Task Group crlteri~? ~ to transuranium elements will criteria. EPA is using conservative dose values in its proposed reconnendations. Informally, EPA staff have indicated that if predicted doses at Enewetak associated with the AECdosoil cleanup criteria are at or near their proposed~crlteria, the~proJect woul~ neet the intent of their guidance. The published proposal nentions Enevetak cleanup but does not make any recommendations specific to this project. Comments on Item e - The statement that the Task Group’s radiological cleanup guidelines considered only Pu-239, 240 is incor-rect. The published scientific report that provided the key information relating concentrations of radionuclides in ‘stribution of transuraniw elements in the soil eluded in the considerations in this report were all of the long lived transuraniw element alpha emitters that would be residual to a nuclear detonation. It was known that the ratios place to place. elements in Enewetak soils would vary fron Even if the rati~ found in soil samples were

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different from that assumed, the same degree of cleanup would ong as t e totals for,the,mixtu.reswere the sam&Aexpressed in units of~radioactivit~. The intent from the beginning was that all such elements woul be included in the measurements of radioactivity m soi+ The mlstafe was Comments on Item f - A much greater intake of coconut (about 10 times greater than used earlier) has-appeared in a report prepared by DNA staff. Comments from DOE to D~A have &aised serious questions about the validity of such~are assumption. ‘We are not aware of the status of the report and whether it has ~ Comments on Item g - The pCi/g intended for use in at Enewetak have pot been the EIS soil levels below recommended criteria of %0 and 400 decisions on cleanup of contaimir~atedsoil changed or made more stringent. In i 40 pCi/gm were judged not to require ~ cleanup. This is still our recommendation. It was recommended c in the EIS that soils having greater than 400 pCi/gm should be ; cleaned up wherever these levels were found.~~s is s$$~$ur ~ recommendations and the value of 400 PCi/g ‘SAW use ~m the cleanup of the Aomon crypt. Islands having soil concentrations ; treated on a case-by-case basis. DNA requested and received additional advice on how to make these case-by-case decisions. I DOE provided the following: Less than 40 pCi/gm - Village Island Less than 80 pCi/gm - Agricultural Island DNA has apparently been satisfied with this. They have not.re- “quested any further advice regarding soil cleanup criteria. 8. Page 19 - DOE is committed to perf~rm long-term radiological followup of Enewetak residenb?sand their environment including monitoring any effluent from the disposal of contaminated

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debris and soil on Runit Island.~y:dm:f ~g monitoring or inspection of theAentomb2d debris CACTUS Crater. Disposal of this debris is a DNA rePages 22 and 25 - DOE would welcome an independent assessrtientof the radiological aspects of the Enewetak project and an independent laboratory verification of soil and offer our full cooperation. Page 23. For comnents on the EPA”proposed guidelines transuranium elements in soil, see comments on item d

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AT BIKINI - ELEVEN SHIPS ON LAGOON,FLOOR. GILLIAM SAKAWA PILOYFISH CLEANUP AND REHABILITATIO1lACTION IN 1969. FIRST 40 HOUSES BUILT, SOME OCCUPIED. ALL NUCLEAR CRATERS UNDERWATER . NO AREAS OT HIGH LEVEL PLUTONIUM IN SOIL. PEOPLE TRADITIONALLY LIVED IN VILLAGE ON BIKINI ISLAND IN SOUTH OF ATOLL. NO EXISTING FACILITIES. TENT CAMP IN SOUTH BUILT FOR CLE.4HUP. CLEANW’ IN 8 MO. LITTLE WORLD WAR II EEERIS . NUCiEAR CRATERS ON LAND. AREAS OF HIGH LEVEL PLTJTONIUM IN SOIL. ALMOST TWICE AS WINY TESTS AS BIKINI PEOPLE LIVED IN TWO GROUPS, ONE IN SOUTH AND ONE IN l~ORTH OF ATOLL. OCEAN DUMPING LEGISLATION . INCREASED CONSERTJATIS1! IN APPLICATION OF RADIATION PROTECTION STANDARDS. INCREASED CONCERN FOR PLUTONIUM . MICRONESIA LEGAL SERVICES CORP , INVOLVEMENT . SOHE WORLD WAR II DEERIS l EXISTING EASE CAMP IN SOUTH NEEDS MUCH

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I would ask specific AEC cor,mentson these points, invit~ng any thoughts that would refute the logic k~epropound. In addltlon, I suggest a meeting with you, and Mr. Stanley Carpenter, . and a limited number of staff members to discuss the alternatives. When this matter is presented to the Commissioners ? re~u~;t. tkley be presented with the feasible alternatives along with ~nLlc\p~ted which can be adopted if we cannot obtain all th,enecessary funds.

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Martin B. Biles, Director COhfhfZNTS ON TASK GROUP REPORT ON In the short …