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. . -.- . - . ieportTo The Congress, . ;_. 1 ,’ --
Nudear Contamination B-165546
r-n&o the President of the Senate and the Speaker of the iiouse 3f Reptesentatiges
The Enewetak Atoll project represents a unique attempt by the United States to clean up an area radicactively con- taminated durirlg rzuclear tests and resettle the peopie. Enewecak Atoll, located in zi-~rYarshail Isiznds, is cart J f the TCISC Territory of t.Le Tacific Islands.
This repox disecsjes the roles of the Tedera!. Pjencies i.r.voivedand iZen~lfr es issues which shculd be resolved be- fore tihe United Scares can consider the project finished.
“h ; A*.* S Ls a re,ctricted report with limited di.stritiuzicc at c;?is t:xe since negotiations between :?e 2ni:ed S:a:ss ani: t;?e Xarsr.aIL Islar,ds -?,7li:ital3t2tzs Cxmissicr. czn- cerniq Zhe OrdinG_. .L_ of the tmsteeship acreemer.t are C'JZ- rently in Ftxjrcss. It is therefsre believed t:c.atrelease Cf this rep3r: vhile neqztizcict7s zre ir:procress would net oe in tke Best interest e,F :he Gcvernmenz.
Xe zre sendir.5 co:ies or Defense, tr.e 1.7.tzribr..
Coinptrcl ler Cezeral cf the Eflited S+.a: es FLJRTt!ERRELEASE OF THIS REPORT ?IAY
CCMPTRCLLER GEXRAL'S ENEWETAK ATOLL--CLFA-‘II\:G REPORT TO TtiE CONGRESS UP XUCLEAR CCNTAMIXA313N
-----__D I G EST The United States acqc.;,-edEnewetak Atoll from the Trust Territory cf the Pacific Islands in i947 to use as a nuclear weapons provirg ground. Before the testing began, the United States relocated the people of EneGetak, ,then numbering 142, to Ujelang Atoll, a mailer less desirable atoll where they still reside. Forty-three nuclear tests were held at t;,-ewetakfrom 1948 t3 1958 leavi.ng contaain;.:ed soi_ and scrap.
The people of Enewctak, displaced new for ,more :han 30 years because of nuclear con- tamination on their island, suffered the physical hardship of living on a much smaller atoll with increasing numbers cf people and the psychological hardship of oeing removJed frcm their traditionai land.
Lana is important to the people of the Xarshall Islands because it is the cnly source of subsistence, social status, ana family unity. 'N'henasked at a con- sressional hearing why a monetary settle- ment insTead of returning to Enewetak was not ac:cepta5le, Enewetak representati*;es replied that money was not and never could be a substitute for their islands. (See pp. 1 and 2.1
In.L 1972, the United States announced it *was prepared to release Enewetak Atoll to the Trust Territory assuming it would even- tua lly be cleaned up ana resettled. m\ir.._s pru,_~'bct isj under-day and is expected to be cenpleted in 19eo a: a ccst cf about SlOO ail- L:on1. to s:.a5 31,"lien. (SE0 pn. 2 ar.b 3.1 . l
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If the Y;lita4 States accoz;lishes a11 its objectives for T' ea.ning c_3 the Atoll, t5e Cnewetak people "1 t '1ot eitkey !:no-.lrizgly or uninter ’ zna?_y vigl-.+.e'J.S.-reco~~:en~?erl li*ring pat -r-lrastri:tions t9 avoid '3ver- exposure r raziation. As Che tin? f3r r5settlenent 53?roac\t5, the secple are less wi1lir.g C. ilefer, 2erhaps for as l2ng as 100 years, r5;aAlishing residsnzes on Snewctalc's sezon3 largest islan?, Znje'zi, until certain radioactive eler=ents no 12nqer ?ose a ra,-!iatioT.5azsrci. GAO also auesti3r.s whether it is realidtic to assme t;?at tk.e peqle of Fnewptak will honor fareTIer =?a pemanent quarzztine cf the ?ighly radio- 73+icallv mntazLnate3 islsn? af ?uriit,
_-: . RECOAMENl?AT1ONS
The Office of Yicronesian Status Yegotia- tions should make every attempt to arri;e at an agreement with the Ms:shall Islands Political Status CommistA. . and the people of Enewetak concerning the nuclear test- related, issues still UR" .Toived, such as:
--Lost land or land use as a result of nuclear tests.
--Lost cash crops found to be unacceptably contaminated witt. radioactive elements.
--Specifying what the responsibility of the L'nited !;tates would be should the people of Enewetak choose not to observe recom- mended living pattern restrictions.
--The course(s) of action to be taker, snould. the people of Enewetak receive exc.tssive doses of radiation.
--The specifics of followup radiological surveys and of monitoring th? healtk of the resettled people and thr- radioactivity in the environment .
--The future status of the entembed radio- activit:(-cont.aminated soil and debris on Runit ak how future nonit0rir.g and in- spsction will be acccmpl ished.
--The specifics of a supplemental feeding program, if required, urltil the people of Enewetak are agriculturally self- sufficient.
The Secretary of the Interior should izitiate an indepel.,-*'ent technicai assessment of the Snewetak cleantip project. I The Secretary of the Interior said the future proolems GAO mentioned are being considered by the Departments of Energy and the Interior and the Micronesian Status Negotiators. The Depart- ment of State replied that the issue of post- trusteeship liability and claims resulti:lg from the nuclear testing program has been raised in the ?licronesian Status Segotiations. (See app. III. )
This report was discussed with representatives of the Office of Xicronesian Status Negot.ia- tions, an interagency off ice tasked with the negotiation of the future political status of the TrUSt Territory of the Pacific Islands. They stated that the issues concerning lia- bilities and clai,ns resulting from the U.S. nuclear testing pr_ogran have been raised .in the negotiations.
The Department of Energy stated it would __ ’ welcome an independent radiological assess- ment of the Enewotak cleanup project. HOW- ever, the Department of the Interior and *:he Ee fense Nuclear Xgenc:/ feel that an indepen-; dent ass2ssment is -not necessary. (See / ?z??S. I and II.)
?he Depart.ments of the Interior, State, Energy, an6 Defense provided other, more detailed comments that GAO included in the bcdy of :he reFort 3here appropriate.
This is a restricted report with limited distribuzicn since negotiations betreen the United States and tha !-larshall Islands Polit- Ic.-al Status Comnission concerning the ending of the trusteeshis agreement are currently! in ?:rogrssri. Th-c issues cf sosttrusteeshi> lia- W_____,C. ’ . _,, 2nc zi.3 ims are aart cf the S:stus ::;ego- -..-= -_.,-_<-.__‘“l.., . It is oeli+*?sc :ha: rpl?ase of zr.ia rs;cr’_ :Jr.:,l2 n;/-r-;=r:-ms_‘_C_..__~L. are ir: ;rcgress xc*;:3 not ‘he L.2 C-P. .._ 2’3: i.ZClf?S; 2: '_.?e aJc,,*_ c2r--rLjr.-_ _ .. ..I-.. _ * ,
, ‘
f? 0 n t e n t s
?ace
1 1'J"WDOCTION 1 The situation i The p!_iqht of the people of Cnel.tetak 1 Pro>Sect responsibilities 3. ?ro>ect funding 3 Conparison of tba Enewet.3'tan? 3ikLzi projects 4 Scope of review . 5 2 W=“\‘TJS _._ CF .2431'3LOGICALCLEXJ'J? C'FOQ'l‘ri 7 ?Ihe Enewetak cleanup and YaSitation alan 7 Cleanup proqress 73 Living Fattern restrictions in Conc?usioi-is &A:1
14
14
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- 4 f’::AI”:CI!ir, ?xl.TfC? CREDI3liI”‘..! -uQW?G’4_... bd I:ID.;?C>i3y?J” .~SS~S.S.‘!~:r!“< Cleanup criteria Postcleanup hazards Con: I usions and yecoivvq4a+;Qn__ 1.._. _ c- Xqency conments
Letter dated January 5, 1973, frm 3eput;1 Assistant Secretary, ?Qlicy, Sudqet an4 Adninistration, T.S. 9egartment of IIT- terior
Setter date? Dec‘enber 78, 1973, froa Actinq Director, 2x0 Liaison, 3epartzer.t sf Enex:f
Letter dated Januar-1 10, 1379, frm Deputy Xssi _UGe+ar.t Secretary f3r 3udget and Fi;?ance, Departxezt of St.at2
>_3s5r’;I.:*“I;!:>_ _\&
n,.- 3;:: Znexy Cs?!-!1~~ i3,n
Zefense ‘.;uclear :.:ency
32--y a ‘+?ont_ -.. of 3efense
Zepar:.?25: of Ener;v _
Zerawtve?:r - .&.’ of the Interlcr
Znvir:jn7e?.tal .iYZaCt Statozezt ‘-.f’ .. c
Snewetak Atoll, located i:: the northwestern portion of the Yarshall Islands, is Dart of the Trust Territorv of the Pacific Islands (T?J?I). The United States acquire? the atoil from the TTPI in 1347 i0 3se as a nuclear weapons proving grounY. In late 1947, before the testing program started, . the Jnited States resettled the people of Enewetak, then nu,nbering 112, oh 'Jjelang Atoll, a consi!erabl*i slaller atoll about 124 miles southwest, where they still reside. Forty- three nuclear weapon's tests were heli at Ynewetak Atoll from 1948 to 1958. The tests contaminated some of the islands of . the atoll With radicactive elenents and littered the other islands with uncontaminated debris.
The ?eop?e of Enewetak, displace.-!zow f.or Tore than 3? years, ha;re suffered both the 2i:~~sicalhar?s?iTs of with a growin? ?ooulation 1.1 on a nuch their hone atoll and the o~ychological hardshi-s of bein? renoved from their traditional lahil. This latter hardsiir? is the great?r burden, as the land is all izportah: to the Xarshallese paople--hot only for su.bsistence, but 2130 f?r social status ahc? far.ily unity. A cor?.?arisonof Ene*+Jetak ahd 3jelang .Atolls in square giles of area foLLc1:s:
Lazooi? DtY lane?
7jelang Atoll 25.37 n .i7 Fnewetak Atoll 337.99 2.75
The 1iTite.d food sroduction_ dotenti31 oh L'jelang +aS ?ale it necessarlr to i.Toort nore Cc?WXiiti~S :+2n :;9lil! yor-all:r oe req.uired on ZneWetak.
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L- - increase3 with tizte. 7ho:r said that fcr the? to live anywhere else in the world would make tnem squatters and . vagabonds: the land, the atoll, is part of them Vand they are part of it, in a way which is difficult to describe. They said every family and every person, including newborn infants, has a specific place there, inherited f::om their Xcestors.
When asked why they do not just accept a monetary i ’ sectlenent instead of returr.ing to Enewetak, the!! replied that money I's not and never can be a substitute for their islands. Thy said it is ag.ainst thsir nature and their custom to sell their land or to take money for it. They . concluded that from their point of view, they cust return to Enewrtak Atoll because it Ls the only place which God has set aside for them and for no other people.
The Senate Ccmmittee on Armed Services agreed to a one- . ti&e authorization of $20 million to accomplish the cleanu;. Although the moral obligation to permit the people of i'newetak to return to their atoll was a major consideration, the Committee based. its decision primarily.on the premise that the United States cannot walk away from the damage done by its testing program without making a responsible effort to restore the atcll so it can again be habitable.
t"RXECT ?.ESPONSI3ILITIES
The tinited States in 1972 announced i: was SIrepared to bs :' release Znewetak Atoll to the TT?I assuming the major radic- active contaminants would- eventuaily be cleaned up and the j island resettled. Mobilization of the project began in Yay 1377 and is ex,?ected to be completed in A=,ril 1980.
The Enewetak project involves three phases--cleanup, rehabilitation, and resettlement. L/ The first ?hasc, cleanus, manac=?d by the Department cf Defense's (DOD's) Defense Ncc:ear Agency (DNA), consists of debris, structures, ant soil reac*isl posing radia tion or other hguman habitation ihazards. The Energy Research and Development Administration
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COHPAXSGX CF T5Z ~NEXETAI:-- AXD EIXINI 13OJSCTS
The EnewezaK* .‘,;roli cle; .lup, r?habilir2ricn, and reset- tlement program was preceded by a similar project at Bikini Atcll. In Cecer;iber1966, the Atomic Energy Commission (AEC) (now part of DGi) at the request of DCi, qreed to determine if Sikizi Atoll and its 1Xjocn wore sa5e For habitation. In April and i4ay 1967, AX made an extensive radiological survelr of the atoll. A year was required to analyze the radiation data and environmental samples collected &xring rhe survey, data from all previous surveys. anl TT21 reqorts concerning the living i:abits and diets of the ;ecFLe or Sikini. Afte-L reviewing all available date, an ad hcc czztittee of eight consultants a_cpointed by XC concluded thrt radiation offered no.sicnificant- threat to the health ahd safety of any of t1i.egecple cf SikizL zho sight- elect repatrlaticz. The corm+-tee. I__ also recomended actions :hat **;c:ldfurther reduce Txaosure to radiation--for example, dietar,- s:us;lements, eericcic s*ur-:eysof t;?e a--_"11, and radLsa::iCe scrap rezoval.
3ased c;? the favorable findinqs of t?~ ad hcc comiitte~ ahd the expressed desires of the pespLe of Z'iI are being constructed on islands zhich are essentially free of radioactive contamination. 752 f2llowing is a partial car!- parison made by DNA of the Bikir.i and Enewetak cleanup projects. --Similarities: both atolls are located- in the Xes:- em Pacific near the international date line just north of the equator. The diet and living habits of both people are about t?e.same--they tend +o live in fzlmily <;roups on tie largest islsnds, grow subsistence crops near the family living area, and develop larger areas,for cash.crops. 1 Birds, bird's eggs, and other edible Gildlife are gathered from the smaller islands. Fish are taken from the lagoon and clams and other shell' fish are gathered from the reef. 2ey are primarily gatherers rather than producers. An extensive survey was conducted in LX::? cases to determine the impact of testing on <:e environment. This was followed by an extensi*:e report of the find- ings and an evaluation of :;?e physical and radio- logical hazards; On both ato11s, the radio- nuclides of principal concern are cesium-137, strontium-90, and plutoni--. The likelihood of an individual receiving a Dangerous dose of ra- diation from external radizticn on either atoll is extremely small because cf the low average of surface radioactivity levc1s. The lagoon water has very low radioactivity Levels, ana the fish and shell fish were found zc have low levels of radioactivity. Ho:.'ever,tze foods :.hich are grown in the soil containing cesium and stron- tium were found to have 'hi;5 levels of radioactivity and were predicted to be tI:eprincipal sources of exnosure. In some cases the ground water contains cesium and strontlzm. --Di ff erences: the differe:cls are significant. At Enewetak there were 43 zests, one of which was a safety test which produced no nuclear yield but a large amount cf ctntaminaticn, ccmz_ ared t3 cnly 23 detonrtlons cn Eikini. Xast of t:-.etests at 31:tir.i;lere over ilater, Fitcr ng :he craters and mcs: of the debris in z?e lscccn._ AZ E;e-*-et::c -_:?p :,ajcri:y cf te’-_:s wprs csr.dilctad CT: CT :*;er land. Ill but :*dc cf :he tes;s '#ere :r: :.?e T.orzT.er?. islands where all the significant rriiolog:- cal contamination is found. 3ur:ng :esti::;, Enewetak had well-established base z-;s ::z support scientific and other zes= lzfz-sonneL in the southern half of the e:olL wti:h is relatively free of contamination, w%reas rll of the islands on Bikini Atoll were zxtas:l- nated, some more than others, by fax-tit. SCOPE OF ZE'IIZW We reviewed the Lnsvetak Atoll clernu;, rehaLill=aficn, and resettlement Ero:ject to identifv 3ignif::ant i.ss~u~s.xLrch should be resolvea before the United Sta-,es consi5er-t the project finished. We interviewed oEiicLals cf agzcFls involved in the project and represeczatives cf thf pe=?lt of Enewetak. rWe also reviewed pertinent fFAs, r5;0~s, and other materials and observed contitiznc cn the atz-ll. The review w2s ;Trinci?allv_ perfcrme.5 E: --ZrNA Seadquarters, Alexandria, 7a. -_ ,noL” Headquarters, Gersantcwn, Yci. --ZOT _ Eeadquarters, Xashingtsn, 3.C_ --Field Command, C&4, Albuquerqz?, 1;. ~5.y. --Nevada Operations Office, DOE, Las =‘~,-as,Sv. --r,ff ice of the High Commissicner, TTFI- Sa.i+*, Yariana Islands. --Enewexak Atcll. CHAPTER 2 STATUS OF WDIOLOGICAL CLEANUP 3FS'OR"S As work progressed on the radiolcgical debris and soil cleanup phase at Enewetak, DNA was unsure whe.ther the orig- inal cleanup plan cculd be achieved. If not, more living patte,q restrictions than initially envisioned would have had to be imposed on the people returning to Enewetak. These concerns did not materialize and DNA anticipates that the criGina1 cleanup objectives will be ccnpleted cn sched- ule and within cost projections. Even thcugh all the cleanup objec'_ives are being met, the people of Enewetak must still cooperate in following the recommended living pattera 're- strictions to avoid overexposure ‘to radiation. TUf h--Y EX'ZTAX CLEAWP AND SAPITATION PLAN DNA .and DOE agreed 5at the cleanup cf Eneweta:r,Atoll xocrld include removal ant disposal of the radiclogical hazar3 so that the people could be resettled safely. They acknowledged that it was impossible to reduce radiologicai contamination to pretest levels. They agreed, howe*ler, that it was feasible to rehatilitate the atoll to asc*TTe_I- the safety cf the returning people if certain.restrictions on land :.se and locally grcin foods were fCilCW2d and z:?e resLZ- 'la1 rad,oactivity was ccntinua!.iy surveyed. The Enewetak Atoll. Xaster Plan divides the islands of the atoll into three categories reflecting-the primary xse of each island. The plan designates .t:lorslands as inhab'-aJ_-L-e, agricultural, cr food-gat?_err.ngsites, as de- cided by the Eneweta.c tJ-*ecple. v-s n n 2 n t:?eEnewetak people learnec that Snjebl Island cclJld ncz be used as a residential site c'de to residual radioactivi:y, thev agrezd that tf,e Enewett:c, .cIeCrez,and ,'aptan islands would be t.',eirresidential sites. Agri- c'J?'c'>T_- _-_ d5velcpmect rI.lI ccmplement the permanent com- 7.u.I__ i ‘.;__ cevsAogceLA_- WC a C t kt 5 e islands. .- --, --F!:e;navP physical hazards from ali islands. --Remove obstructions to development of habitation and agriculture. --Remove radioactive scrap from all islands of the atoll. --Remove plutonium concentrations greater than 40G picocuries per gram from Roken, Lujor, . _ and Runit. Concentrations of less tnan 40 gicocuries, per gram were -?Qt to be disturbed. Concent.rations between 400 and 40 picocuries per 3ra.n were to be dealt with on an indiv:.- , dual basis. L/ . --Remove ?lctonLum from the three burial ~:ypts onk Xomon. --Du:;;l;, unsalvable nonradioactive. and noicox- bustikle material irk the laacc? a-t selected ;oca:icns to for:2 artificial reefs. -Yix plutonium-c ontaminated c-oil with. ce.nent and water u form a sll*,-rv 2/ and blace it in a crater on Rcnit_. ?.lso &iwp rad ioacti7e der;ris into the cra’fer. Tke habita:Lon plan provides that the ?ecsle of Enewetak live and ootain food as fol’_ows: --Res idprice restricted to the soukern islands; .Jinedrol throuqh Kidrenen. --Runit guarant.ined indefinitely; nc other res:ricciGns cn travel. --Cultivate pandanus, breadiruit, arrowrcot, and o t .?e r svubjsL9C”-c0-c-.. _ focd sn the southern islands onl:,: f i i 9 southern islands and the northern islands of Mijikadre X through Billae. L/ The north- west islands cf Bokoluo through Enjebi and Runit were not t7 be cultivated. --Raise liyestock to be used for food cn the s0uther-A islands only. --Eat coconut crabs taken from the southern islands.only. --Eat fish from the lagoon and wild birds and their eggs without restrictions (except for Runit). . CLEXIYUP PROGRESS At the time of our visit to Enewetak in !!ay of 1978, DMA was not sure to what degree the original cleanup plan, as outlined in the Enewetak Atoll EIS and later revised by the Enewetak Advisory Group, could be accomplished. 'N'iththe project now ,abou: 60-percent completed, GI1A is prcjecting that all major cleanup objectives -gill be met or exceeded. For example, the island of Enjebi which was planned to be cleaned of transuranics 2/ to the level of 80 picocuries per gram, has been cleaned to below 40 picocuries per gram. Only the island of Runit in the 40- island atoll will be quarantined. DNA anticipates that all cleanup e,&:;orts can be completed on schedule and within the planned funding level. LIVIK PATTERN RESTRICTICNS The Enewetak Atoll EIS contained a habitation plan list- ing certain living restrictions for the people returning to the atoll. Because it is impossible to reduce radro'ogicai contamination on all the islands to pretest levels, iiving _ 3attern restrictions will have to be imposed on the returning Enewe:a_k zeople. E ve n t?.Cc~h XX is accomplishing 211 the cleanup CEjP ctives of the Enewetak A:oll Yas:er ?:a,:, the -- people could still be overexposed to radiation by knowingly or unintentionally failing to follow recommended living pat- tern restrictions. How long these living pattern restric- ’ tions will be necessary is not known. Therefore, the peoples' cooperation is needed if the resettlement effort is to be successful. D/3E plans a long-term radiological followup of :ne peo?lJ and their environment to determine.if radiation doses are staying within acceptable limits. CGNCLUSICNS As work progressed on the Enewetak cleanup, it appeared that a modified solution to the radiological conLamination problem cn the atoll would be necessary. However, this has not prov. NEED TO RESOLVE TEST-RELATED ISSUES Some test-relz*:ed issues remain unsettled and need to be resolved soon. The issues include, but are not neces- sarily li;nited to, loss of land, loss of land use, loss of cash crop, radiological monitoring, the need for a supple- mental feeding program, the observance of living pattern restrictions, and the ac.tions to be taken should the people of Enewetak receive excessive doses of radiation. The ex- pectation that the 'IITPIAgreement will end by 1981, plus the fact that the future political status of the Marshall Islands, of which inewetak Atoll is a Dart, is uncertain, further-complicates matters. Some of ihese issues are presently being addressed by the Office of Nicronesian Status Negotiations. The Enewetak people.have been pr.id various sums by thi L'nited States for use of the atoll i.nd for war damage. These payments, however, have not included amounts for danage re- lated to the nuclear testing prograin. COXPBXSATION AWARDED A\ND PAID TO T.q.ZPKGPLE OF ENE;$ETAX In 1956, 9 years after the people of Enewetak were relocated by the United States to t']elang Atoll, the TTDI. paid the pecple S25,O!lO in cash and 5150,000 in trust for use Of the a:oll. Li1 1969, TT?I paid then another $1,020,000 in trust for (1) the hardshi(?s thev suffered as a result of being displaced, (2) their continued displacement in the foreseeable future, and (3) the decline in productivity of subsistence agriculture. In 1976, TX?1 aeraanently trans-, ferred title of Yjelang Atoll t3 the people of Enewetak as additional consideration. Also in 1976, the Micronesian Claims Commission awarded the people of Enewetak aoout $3 million, pursuant to titles I and II of the Xicronesian Claims Act of 1971. L/ The Ccr.- xn13sicn’; decision s;ec:Eictlly prcvided that none cf t:7e 3 wa r d Y a s far 12s: use cf land or Za.7age scc!2rring after 1251 ; Gvlc=; and rL_ _ :I rlla:& i:: W&Pb.. _ a:cmic :?stinc’ CT^,C~~.T,. ” .?-2 ;ec;ls cf Z;,evetak wer;2 ;ai2 250~: Sl.7 “1-J.’ -. ,-La.. ,T; tP”3:;CI _ -‘--_.._ awards considerably exceeded the amount of funds then avail- able Lnder th.e Hicronesian Claims Act. In 1977 the Congress authorized the appropriation of such additional sums as might’ be necessary tc satisfy all adjudicated claims and final awards under the act. In October 1978, the Congress appro- priated $12.6 million to pay the outstanding balances of the Title II awards, including about $1.5 due the of Enewetak. ISSUES Loss land DNA that about acres, or 8 percent Enewetak Atoll’s was lost a result nuclear weapons . ?he reportedly vaporized islands and large portion another. Representatives the people Enewetak told in flay that the States should for the land. At one island contaminated with elements from nuclear tests expected to quarantined indefinirely. may be for the desired by people of Any issues concerning loss of use, cr loss of intended use, of some of the islands should be ad- dressed and settled before termination of the TTPI Agreement. Loss of copra “cash crag” Copra (dried coconut meat) is the traditional “cash crop” of the Harshallese. Coconut trees to be planted on Enewetak Atoll during the rehabilitation program will take 5 to 7 years to begin producing nuts. The Enewetak Atoll Master Pian of Xarch 1975 estimates that copra could bring the peop’?e of EnewetJk about $lOO,OOir a year at then- current prices. The planting of coconut trees on Enewetak’s northeastern islands has been delaved because of the aikini experience. As early as 1974, Environmental Protecticn Agency (EPA) ex- pressed c3ncerx about planting coconuts cr. the northeas:ern 13 Lands. Its cosition *was tnat ccconut przduc:ion cn :hose ls.lands snc~ld 3e Jeferred unless there :s no practicacle a_:er:: a : :.*,- c t3 prcv ;Jing an adecza:e +*,_PZ, or ra --the particulars of testing cash crop cocon~uts . fcr rad ioac t ive eAener.ts up:a:ke; --the .?lethoc? of disposal if the copra is found to be unacceptably contaminated with radio- active elements; and --the amount of compensation, if any, for such loss. :ieed fcr a provision specifying the L’nited States’ responsibility if the E;eople of Enewetak cnoose not to observe -- reccm- mended iiving pattern restrictions Several restrictions regarding living patterns, the growing of foodstuffs, food gathering, etc., were srocosed to and accepted by the people of Enewe tak. Ir . returning the people to their home atoll, it is assumed that sue?. re- strict ions ‘will be obserred. .A: t:lcuc~~_.A lx:, :;?rocc.‘! ?“?I, i3 r2sFcnslble kor enforcing szck advisory controLs, tnis ar- rangement is temporar*J since the T’i’?I Agreement will SOOI; endEne.iet2f restrictions are not obser.Jed, the seo~1e cf -1. could rer;eive excessive dcses of radicac:ive e:e- . nents as d ic scce 0 f the Feople whc returned to Bikini Is- land. As the time for reset:lement approaches, the ;eozle 0: Cnewetak are iess w iiling to defer (for ?erhaas as lbng as LOO years) establ_i.shing residences on Enek.eta:k’s second lar:ec: island, Znzebi, until certain radioactive elements nc A0 r.g e r sose a radiation hazard as originall:; agreed. -c_..e - L’ ,” . ited States does not ?:a:: to ciean u; all the rsiands of Enewetak Ato’ .&1 tc t ;he saint w:.ere 7.0 restrictions ~ccld halie to oe i.z~ose2. mhQvef9re,L., _. it is i.-n.Fera:ive t:;at a =- ‘^‘J;s_ ” i2.n. be made specifying the L’nited States’ ressons i- ^. ‘. M.) v--A__, 5;:CClJ :.-.I=_ y_-PC- k-2’ C, Enewetz.:< ,-.;‘.ocse ret t3 C~S?T~I? .-a --c-?~-. _ _Lrll.,l+ _..ets .b* _* .-s ““5-‘- ;a::2rn r”S’z1;,L~xZ. - c people of Enewetak could receive radiation doses in excess of current standards even if they adhere to living patte--n re- stricti’ons .’ Further, even if the people of Enewetak do not receive excessive radiation doses by current standards, their doses could eventually be considered excessive should rad ia- tier, dose standards become more stringent. According to EPA sources, there is a good possibility that will happen. We believe representatives of the people of Ene+,atak and the Gnited States should agree, in advance, on what course(s1 of action will be taken should either of these possibilitie? become a re:ritj. Seed for aqreement on folI.owu~ radiological survevs--- anJYonitorinq DOE assumed responsibility,. including fgnding, for future periodic followup radiolzlical surveys of Znewetak Atoll arrd 7 for periodic monitoring 0,6 the health status of the resettled : peep le. It also is responsible for monitoring the radicactiv-; it; ir: the environment after rehabilitaticn. These matters i i ye vitally important, because only through followup monito? / : ng can poten:ially harmful radiological situations be de- tected before becoming an actual hazard. The United States, however, has no official agreement vith the people cf Enewe:&’ regarding these matters. Such an agreement cculd a*;ert pc- ten:ial future conflict regardin; surveys and monitoring azd xould assure that any developing hazardous radiological ?rcb- 1em would Se detected early and dealt with quickly. ; Xeed fcr agreement t9 man_ tor--. and ins3ec: er.tombed rad ioac ilve --soil an,’ de3rls The radioacti?le scil excised from Znew‘etak Atoll for cisp osal Xi11 be entcmhed on the atoll in a crater on ?,unit Island. The island will be quarantined indefinitely. The soil, mixed with cemenr and water to form a sorl-cement slurry, wil 1 be placed in the crater. Xad ioact ive deb,r is will also be dumped into the crater. An 18-i nch thick csn- Crete cap will be placed over the entire mass fcr erosicn resistance and as a shield from ai?ka radia:igr.. ?!i,“razizr. viTZ 3cYie ~l~z:x,lSi! ;art;c:+s tc the scrr3ur.d Inc 2zvirzr.nez: ccLlz cccxr since ::?is ae:zcd of er;cm2LnG, sr zontal::7.q, :.7C ccn:za:.za:2d ma:srial :s zot leak-grcof. .A..7*,. s:ch Tl:,;r2-_i:r. ml., - A.2; - zct 2x-,eczed tz ;o;;o a nazard. _.._= metticd ,of con:2in.?E::: x:.ll rscuire_ ?eriedr: acrL:3,rir.g a-6 l?s;,esz:cr! t2 =--.‘rl_.._ __ LFS _“--~_*‘_: “?3C’1 “I. ccs 15 ms;ccsisla fzr yp~::~~cri.?~ zr.11 *ffl,:or._ _ fr>n ti-ie dia;osal of radioactive debris and soil on gunit Is- la!:3. _ Zhey st -ted, however, that this does not include moni-: torir.g or inspecting the engineering features of the entombed debris. Kith tht termination of the TTPI Agreement, tr.e United Sta:es *dill Se leaving a radiological contamination legacy cn foreign soii. Xowever, tnere has Seen no agreement be- tween the SeOFiPS 3) Enewetak and :;?e United States CT: the future status of t?.e entombed radioactive soil and debris cr how to accomplish future monit.Jring and inspection. Su;clemental feeding program ZnKii the agricultural system provides enough food fcr :i?e :eo?ie of Enewetak when they return to their home atoll, the Linited States may need to initiate a su?plenental feeding r;rocram to fill tne void. The sossinle extent of the feeding crcgrac at this ti.me is uncertain; bowever, tne sartic3iar.S Cr' the grogram, including the cri:eria for starting and end- rng it, could 36 resolved. can .+ar,diy . affcr, tc lea’14 several significant issues related :3 : .-ie i n e 5;e t a 1; C’ A__.“AI-CC ~ program unrescl*Jed, since the TT?: .:.gree,mer.t is 2eir.g terminated. T‘kEJS? issues include : --Lcsz land u?r land use as a result of nuclear tests. --Las: cash crsss fourid to be Lnacceptably ccntazinated 2;t2 radioactive eiesents. --S;ecify:T-lg *xkat tk:e reS~CnSi~ii;t~/ Cf ::ie United Stzc_es wccl2 ce sbculd :.ie ;scG:e cf Enewecak ckccse net t3 ctserve r.eccmmended li*;i2g ;att*rn restrit- tions. . - -2 --The future status of the entombed radioactivi:y- contaminated soii anti debris on ilunit and how future monitoring and inspection wili be accomplished. --Ths specifics of c supplemental feeding program, if required, until t2.e people of Enewetak are agricul- turally self-sufficient. The @.?f ice of Xicronesian 5;acus Zegc tiations and the acencies_ principally concerned are considering these and other issues that could arise from the L’nited States’ past nuclear testing program and related activities in the Clarshall Isla+s. We recommena that the Office cf LXicronesian Stat;is 3egotiations make every attempt to arrive at an agreement with the Yarshali IsLands Political Status Commission and the people of Enewetak r.or‘.cerninq all of these issues. AGESC!! CC)M>!!EXTS DOI stated chat the future srcblems we ment ior,ed are generall*l being car,: idered by DOE, DOi, and the Xicronesizn StaiUS Xegotiators. ,:le SCate Department replied that the issue of posttxsteesiki? lihbiiity ar-lc: cl2i.TS resulting frc: the ‘*“.S. -Bv-lear.&LU_ testing prcgram has teen raised in t.‘e Xicrcnes ia:: Stat.2s Negct:ations. 2ley sta:2d th.at details? provisions have not yet set?n discussed and it is i.mscssible at :nis time to zetermine what degree of detail the 5.S.- Xicrsnesian Compact of Pree Asscciation will contain. TH,90U~Z ISEEDENCE?IT .;SSESC*‘=U”“=L.._. *Y Sicnfficant_ - raiiological aspects of the zlea~u? portico, Of r:?e Enewetak Atoll pzoject have not keen indezendently . assessed Sy organiz2zions with no connecricn 3:: interest ir. the xclear testins zrccjran. This situation cczld conceivably raise questions on t&e objectivity of the Frcjecz. IndeFer.- dent assessments are, in ouz- opinicn, unequivccally dictates’ 1%“_I/ tke ix;or:ance of t:‘.e sro:ect t3 the =ecs;les zf Enewetak . ‘a r:d the ‘United States. Supccrtinc this iL3 the :ecent Bikini izclient; t:“.e tincerzain, long-terz effects of ex;osvre to low level radiation: and firtally the ;rDject c~)st, x:?ich is es- t icazed at z.jout Slit nillior?. SPA has analyzed the potential hazards to individuals in the general population resulting from present levels of transuranic elements existina in the envircr.s A/ of at least one other location. It examined the various pathways into the human body that radiation might take if ex?csure occurred under present and projected land usages interpreted in light of its proposed guidelines for exposure to :ransuranic ele- ments.. ETA, however, has not been designated to technically assess the Enewetak Atoll cleanup. A radiochemistry field laboratory under the direction of DOE has beenestablished on Enewetak Atclf to support the radioJogica1 protection program and the ?lu:cniurn soil analy- sis 0Ferations. Representative soil sampler are anslyzed by the laboratory for americium and plutonium concentration data. Documentation of soil concentrations is essential to DOE's final certification cf the radiclogiczl condition of each island. There was no qualitv control _=rogram by an in- dependent laboratory verifying soil sam?;les.., Because of the importance of the radiological cleanup of Enewetak Atoll to the people of Enewetak and the United States, the recent Bikini situation, and the recognized uncertainties surrounding ra.diation levels 2at constitute a hazard, we recommend that the Secretary cf t;he Interior initiate an independent technical assessment of the Enewetak cleanus project. DQI should initiate this t:tion, since it has the ultimate responsibility for rehabilitation and resettlement of the Enewetak neople and mus: handle any prcblems that may develop during the intervening time before the TTPI Agreement ends. This is evident by the recent Bikini incident where CO1 was res?onsibie fcr the funding and action ?lan to again resettle the gec?le. -i; = .rr -,._;; _c =?-a= & _.._ _.d_ -rL..c._.._ ____. 3NX acd DOI, however, feel that an indecendent zssess- ment is T;ot necessary. INI scztes tht to cib so would mear! .. contracting Xith essentially tke same research instizztions currently keirrg used sy WE. S!I‘Ast3tes that both ECE and DOD cave mate, an2 are r,aking, continual radiological as- sessments c=-_Ing a k-ide variety of eqerts, including numer- ous indeseneent aces. (See aF;s. I tz III.) X2 * foci, howeve t , t:',atthe radiological assesscents are keing made by eXployees of 30E ar.d CCD or contractors working for :hese agencies. While.we d.o not cuestior. the ex;er:ise of creditility of these excarts, we-believe that tiis. sit*2a+;._:n cocli cor,ceil*abi_vraise c_cesticns on t;?e ccjeczivity 35 the 7rcjecz. Ke kelieve ::?a: ctker experts w.'10kave no direct zornec:icns with the r.3clezr testing program cr ::-.eEnevetak cleanc; project should Ferforn an inderenden: zssesszer.= cf tke cleanuc cri:eria and t:?e _cost- c~ea.:c:_37 >;a---- ,=_Js ar.2 re;orz to I?01 be2:re reset:lemenr Of the ;eO?le kesins. T’-_..L_ i c indecendezt zssess.mect co;lld be zade 2~ recit;lizs ICE's rzdiol:Gical s:s;orz 5ata for the :=;=--,_L_. APPE?GDI-X I 4PPE:7CIX 6 United States Department of the Interior OFFICL OF TM SECRETARY WASHLVGTON, D.C. 3240 !lr.’ J. H. Stolarow, Director Procurement and Sys tern Acquisition Division U. S. General Accounting Office, Room 5415 Ul G Street, ?Iu Washington, D. ,C. 20X3 3e’ar Llr. Stolarow: The draft GAO ReTort, “Observations on the Project to Cleanup, Rehabilirate and Resettle Enewetak Atoll” was reviewed with interest by apprcpriate offices of this Department. khi le tSe report addresses itself primarily to the cleanup program which is being carriad out. by r5e Deparkenc of Defense (DSA), i: is recognize6 that the rehao,, “itati0.r and resectlezent aspects . . cannoc be alvcrced from r.ie basic cleanup aspects. Our cements have been divided i;lto tvo sectior.s, one v.lic!? deals vfth the recommendations thar: relate to the r2habititatisn aspects, th2 ocher lists corrections for the text of the report. I hope tSat these co[*?,enes will Trove to 52 us2Zul for t52 sreparacion of the final report. Policy, Budget j, Adainisfraclon ~xlsscr2s (See GA3 xite 2 on p. 24.1 Ccx?!Eh~s ox RECG”:*~‘~TICNS ACDRESSEDTO THE SECRET.iRYOF THE TIJTRRIOR . Is a modified solution ;J ch~’ or~b!rms acceotsblr :o the neco;c. c’ Lnewetak as we!1 as the L’niced Scares It should be noted that all phases of the EnevecJk program have been discussed vlth the people of Cneuetak. An Enrvecak ?Ldnning Council vas formed by the people for this purpose. This Council, along vith the Lagal Counsel for the people of Enevetak, meets reqularly vith re?resen:atfves of DOD, WE, and the T;‘?I and DOI. The Planning Council has been involved in all asoe-_ts of the cleitiup. rehabilltaticn and resettlement planning and the :mplementarion aspects. Y!jot decisions Jrc xde only attur the Enevetak ?I.lnnfng Council Is in agreement. For example ,.zhen it vas found tsar the northem island ol Enjebi should not be used for residential purposes imedf-acely, ft vas the “Enevecak ?lanning Council” that crude the decisicn chat a!1 of the residences 'd\)Ui.!be On Che UnCOncazhate.. southem islands Enevetak. ::edren Japtan. The tncer-Agency’meettng tn the Snevetak Csunct’, tooiC Leading rola held on rhe veek Decenber i, -- Ccczensa:ion for !.*ss of tbelr cssh croos if the cross APPE;;DIX I APPENDI: I the restrictions recotwnded by the Department of Energy. Sfmilar pledges could be obtained vhen all of the cleanup and rehabilltntion vork is completed. The Department of the Interior feels constrained to point ouc the impossibility of demanding “fosnal unqualified assurances” short of the United States Gmerament or the new merging Marshallrse Government keeping a permanent security force on the atoll to enforce restrfctions. Reliance must be placed upon the representatives of the people themselves. -- :he specifics of follow-up radiological sumeys. of monitoring the health of the resettled peoole and the radioactivity in the environaent, and of periodically uonitoring and inspectlnqx entombed .radioactively contaminated soil and debris on the island of Runit I These specif& aspects are the responsfbility of the Departrent of hergy. Long range plans call fcr this type of monfrorlnq to be carried out by the DOE. - the future status af the entombed.radioactivelv concaminared soil and debris and hov future nonltorinq and inspections can be accomplished ibis aspect is the responsibility oi the Department of Energy and the Departrrent of ttre Interior yields co that Departaenc for corzaent. -- the specifics of a suppieaentll feeding 3ro4r50, if recuired, until the tirnc the people of Enevecak are aqriculturallv seif-sufficient 3e Trust Territory Government and the Depart;aenc of the Ln:erior are exploring this aspect vlch the people of Eneuetak and their legal counsel. The Departoent of the Interior, on behalf of the Cwernmcnc of the Trust Territory, ufl? attempt to vori out satisfactor:? arrangements for a supplemental feeding prcgran should this prove to be necessary. The! Secre:ar*: of :he Tntcr?or should have an aoorooriare indeoendent orqanizacion assess: 23 T!te Secretary of rha :r.cc-tor. shotl:c! ;lcr\ icir ;;ltt. indrpcnden- - Laboratory quzllcv control C!I~LC!XJoi tlr<* i,li 1 <.mnles which ATP essential CO the itxll cer:ificrcicn ,,i t!w r.;L:!Llio.uical c~nJi:J:n.’ of each island. s?.c YiGt2: 1. Sme of th2 acjency cements relate t3 mtt2rs in the ?ra-Ft report which ha.Je Seen revised as sxgested by the aqercy CT omitted from the final report. 2. T,L.eenclosure is not ir;cluded k2re. Pare..L_ appropriate, the Z-2PGrt t-ias SPPFI c.;;anged tg reflect consents in th2 e:- closure. APPEXDIX I I APPESDIX 11 Department of Energy Washington, D.C. 20545 December 28, 1978 Mr. J. Dexter Peach Director Energy and Materials Division General Accounting Office Washington, D.C. 2038 , . Dear Y!. Peach: We appreciate the opportunity fo review and comment on the GAO draft report entitled “Observations On The Project To Cleanup, Rehabilitate Xnd Resettle Enewetak Atoll.” Our views with respect :o the draft report and the recommendations contained therein follow: 1. The draft report notes in several places that the po:eorial exists for future legal difficulties because of loss of land, loss of land usage, loss of cash crops, and the absence of long-ten agreements with the people of Enewetak. In Chapter 3 the report .Jaguely indi- cates that the idgal difficulties would be in the nature of claims against the .Gnited States. However, the report does not elaborate on :his point. There is no indication under what authority such claias could be made. t’nder the Federal Tort Claims Act, any claims arising out of a dis- cretionary function of the Government (28 LSCA 2680 (a)) or “in a foreign country” (29 USC.4 2680(k)) are specifically excluded from coverage by the Act. Of course, the most obvious of these as far as claims from the people of Enewetak goes would be the foreign country exclusion. The Courts have held :Sat the phrase “in a for- eign counc$’ in Sec. 2580(k) is use 1 with the meaning dictated by common sense and common speech. Places that have been held by the courfs to ccnstitute a “foreign country” *&thin the con:.emplation of the exclus izn include the Pacific Islands of Okinawa, SalFan, and Kwajaloin. 1: is, :hereiore, reasonable co assume that Fneezetak vouid surely come :he exclusion. 123is la history zf Federal Torr .&zt discloses Congress excluded arisin3 “in forei. coun:ry” liability under Act -das be decelmined accordance with law of pIace vuhere act or occ*urred” and “vas ucV;illi=g subject the jtates co depend53 upcn lavs of foreian paver.” , Congress expresser! i .?%i?PE::Gr’fA.1 II the clear intention that claims for property damage, personal injury, or death arising out of activities of U.S. military and civilian personnel abroad are to be dealt vith by administrative or diplomatic means, or by special legislation, as may be appropriate, rather than by litigation under the Federal Tort Claims Act. One area that could possibly provide limited relief in a foreign situa:ion vould be the Military Claims Act. However, lfzited claims from foreign claimants are alloved only if presented vithin two years after each claim accrues. See 10 USC.4 2731 et seq. ’ DOE believes it is misleading for the draft report to indicate that the potential exists for future legal difficul:ies In the claims area uithoue specifically eiaborating on what those difffcul- ties may be and how such claim my be made against the Knired States. 2. The concept of “enforcement” O’P living pattern restrictions is foreign to past thinking in the development of cleanup and rehabll- lcacion criteria and recommendarions for Enevetak. DOE has not required the Trust Territory government or the Enewetak people to give “unqualified assurances” of compliance with restrictions. The radioiogical criteria and recommendations set_ forth by .AEC anticl- pated the exister.ce of a spirit c. cooperation among those vho are trying to help the Enevecak people return to :.iefr homeland and that the people themselves and their advisors vouli cooperate. iC vas expected tht the recommended restrictions themselves, and to some extent the need for restrictions. vould be understood by :he people. The Enevetak Fnylronmental impact Starement (EIS! provided the mech- anism for obtaining agreement from all parties. Xbsolu:e compliance vi:h restrictions ‘JTI~not expected. bather, it was anticipated tha: over t:?e long ten the people vould police themselves and a good ?evel of compliance with restrictions vould be achieved. It was e.xpected :bat at least initially there vould be a high level of compliance vLth recommendations on housing construction and planting of food crops because these would be done by U.S. agencies. The safeqluard f or the long :erm vould be :he radiological followup of the people and their environment, to be perfoned by WE. This vi:: Trovide t:?~! necessary assurance th3t restrictions vere being folioved co an acceptable degree. 3. 3CE :?as not changed :he radiological protec:ir’l hilosophy used 0: made acre s:ringenc any cf ::he recommended radio!oqi:al cri:e:ia developed :kerefrom for planning and ccnducting cleanup and rdhabll- t:9:1c:. ~5 Zneve’ak_ . The iievelJpnen: J:’ the jcr! cleanup --irari’-.-L-_-W, L.2. ( the ;iJ and GO pCi;g, vas ‘based ‘upon :onsidera:tsn of 3ll APPSNCIX II transuranium elements in soil, not just Pu-239, 240, and using a conserrativa application of Federal standards. The consideration of all of these long-lived alpha emitters vas not stressed in the AX Task Group’s report and the report used the term “plutonium” rather than “transuranium elements.” This point was cleared up in discussions vith DNA staff. The radiological criteria recommended for planning purposes for evaluation of land use options were based on a conservative app!-r- cation of Federal standards. These have not changed. Also, cri- teria rccomended by AK for soil cleanup vere not changed by EpA’s issuance of proposed guidelines for transuranium elements in soil. It is expected that cleanup of soil according to AEC criteria vi11 meet the EPA guidelines. Further interpretation of the application of the 40 to 400 pCi/g criteria (i.e., vithin this range), which had been left by the Task Group for a later determinatlorr, vas done vhen requasted by DNA. Hovever, there vas no change in the basic criteria. The only change has been DOE’s recommendation that certain islands in the northeast of the Atoll that vare to be planted vith coconut, not be planted. This recommendation vas based upon very recent experience at gikini Atoll. 4. Zeal:h considerations, and the associated as&ssments of radiolsg- ical condi:ions of islands, the application of recommended cri:eria, and the development of recommendations, must take precedence over the people’s preferences in decisions on land use. ‘nhile DOE support5 the full participation of the Eneverak people and their advisors in decisionmaking, it would be a mistake to give the impression that they vi11 decide vhere’ they vi11 live and vhere their food vfll be grow. If instead of a good level of cooperation, ve uust assume little or no adherence to restrictions, the planning assumptions inherent in the EIS and the agreement that the people may be re- turned safely are voided. The Enevetak Atoll master plan contains the peopie’s preferences regarding land use, but the actual use will depend on the degree of soil cleanup actually achieved on var- ious islands and on a statement of permissible land usage issued by WE in the final certifxation process. This certificaticn vi11 be based on an assessment of radiological condirions at the end of cleanltp. _ 3. Ve !Jelie*:e that UC consider revlsizg tSe report tc delete state- ments concerning eniorzomcn: of restricrians and ins:ead 3trsss the posir:ve aspects cf :his project vhere many parties are :zsp- erarinq in a long and difiiculr task tha: pushes the liti:s of technology and :-here there is no applicable precedence. ‘L’e believe the stateaenx rha: !XE has s$anged :he :l+anup :riterla and zade ^_ ,; I-. - ic more stringent, thereby making cleanup more iif ficulc and emen- sive, should be deleted. 6. DOE would velcome an independent assassment of the radiological support that has been p-ovided co DNA and DOI in their cleanup and rehabilitation activities at Enevecak Atoll and of WE’s plans to provide needed followup in the future, and ze offer our full cooperation. Xezbers of your staff have &en furnished comments directed at subject areas in the report where, we believe, the facto as ve know thea a;)?ear sot to support the statements in the draft report or vhere our kfor- mation suggests that the report may not be complete. Ue appreciate your coxideration of these cozznents in the preparation of the final report. We will also be pleased to provide any additional information you may require. I St&erely, ? 2 hnald C. Ces:iehr 44 : i Ac:lng Director CA0 Liaissr. GAO r.ote: Some of the agency ccznents relate t3 mat t2r.s in the draft zecort which ?a*/~ been revised 2s sCggef:ed by ti.p L,=-=r-*~ _..L_ or omitted from the final resort. A?PENCIX I I DOE COM?!XTS ON GAO.D&.PT RETORT "C'BSEXVATIONSON THE PROJECT TO CLE.~UL?,REtLWILIiXTE AST XESET'ZZ EX3ET.U ATOLL" 1. Page 3 - There are at least seven rather than three phases in the Enewetak project: a. The lnitiai radiological and engineering surreys ard asscss- ments conducted by DOE and Defense Nuclear Agency [DNA). b. Development of cleanup criteria and recocnnendations by DOE. C. Environmental Impact Stateoenc (21s) development and ?roject/ Budget defense by DOE, DNA, and Departsent of Interior (DCI). d. Cieanup field operations and disposal of contaminated debris conducted by DNA ti:h radioiogical supl;orc provfied by XE. l e. Housing and agricultural rehabi litation perfoned by DOI *dir-h logistics support from DNA and technical support and advice provided by DOE. . f. Long-term radiological followup of the environment (except for the engineered features of the CACTUSCrater encryptment of contalninated debris on Runi: but including nonitoring of any effluent iron the crypt) and residents of the a:oll by DCE. g* Engineering followup of CACTUS Crater debris disposal on Runi: by DNA. 2. Page 3 - The idea of enfoicemenc of restrictions upon Enewetak residents is foreign to AEC/EiUA/DOE thinking and we have never used the concept or the terz. Recomendat Ions for restricrions on iand and food use at Enewetak have been made vith the expectation thar there will be a spirit of cooperation and a good level of compliance by the people. If 100 percent cospliance *J-.,4-h restrictions vere required in order to be able to agree that the people vould be adequately protected, the resettlement should not be attempted. Ye suggest avoiding use of the term and the concept of “enforcenenc” and recorrnend instead that the GAO report stress the cooperation that is needed if the resettlement effor: is to be successfui. 3. Page 5 - The single ~lost inpcrtant recomzendacicn of :hr XC .Id %c Committee vas that the first houses and food crops 5e pla~ad :K 5-e.; island, the second largest island in Sikini A:oLl. Csmp:iance *ilr5 :his most basi: reconunendacion -Gas poor since A3 nouses *iere con- struc:ad on ,3ikini Island ac the insis:ence of the 3iXini peopi? and 35.000 :oconut trees vere planted on Bikini and Enr?u Isiants. Yhen :he people returned and :heir radia:ion exposures were izcraa~lng they were :Cid they sfiou:~I zoc eat coconufs frsm 3ikini is:3i!d. The 3;‘<;-i a~erioncz il Compliance vich :his precauciJn was poor. -. -.. . r -_ .QTE?IDiX I I II lack of cooperation and failure of the rescricrion to contzcl expc- I sures is directly applicable to Enevetak. Us believe that the GAO report should be mre explicit as to vhy the Bikini resectlec.ent effort has been interrupted. h. Page 6 - There is a better listing of sizuila riries and differences for Jikini and Enewetak Atolls. See Enclcsure I. Csmencs 31: :hc DNA list follow: SiPilarity, we believe, should include the statezen: that all islands at bcth atolls vere contaminated. Some islands were mre contaminated than others. Islands in the south at Enevetak Atoll vere lightly contaminated. Dffferences should state chat zest (but not all) tests at Bikini vere conducted over -dater. Also, sre believe a cczmenc is needed on the mterlal at-*’-.,buted to DNA that discusses the isotopi: con- tent of the concatination found on Bikini and Enevetak. 9ur data indicates chat isot~pl: content of scrap and scils 3: these,‘t*ic atolls is not different enough co support :he p The basic radiologicai survey o f Enewetak was done in 19;%-73 and the AEC Task Group began its !:d’, on CieNlup criteria concurren:ly with this survey. The basic recoinendations fro3 AK were issued in the 1974 Task Group report. ‘I! is repott azd the tnforxatior: f:: :he Enewetak Environmental Impact Scacemenc (EIS) char: was base? on this report are now four years oid. r)uring that four years =IO~C radiological zaeasurments have been aade in the atoll than iuric:: all other surveys combined. se believe, therefore, it is fort-n- ate there have not been more changes tn the original AX recomen- dacions than the one chang e on planting coconuts. 6. Page 10 - We suggest, as an alternative to emplacenent of the s:urry and radioactive debris in a crater on Runlt Island, that conslder- ation bc given to disposing :hose wastes in the ocean. .fe believe that the fnvir~nmerxal Protection Agency (ETA) is in the process of issuing related guidelines. 7. Tage 12 through 14 - ‘Je believe that these pages contain e.rors 52 fact and some of the conclusions drawn are not st?portabl+ as I follows : . --::em a - The only developmen: requiring a modifies soiution zas tLe aikini experience which led DOE to recommend against planting COcOnuiS on the northeastern islaods. There !ms been co ocher change in land use recommendations or living pattens res:ri:ricns from X3E. This iten vas covered in earlier cements addressi zaacerial on ?a;e 9 of the GAO draf:. ‘:ce!rl 5 - 20OEphiiosophy relative to radiological cleahup ar.L re- habilitation of Enevetak Xtoil and recowended radiological :rr:zria far cleanup vere fixed with the lss*uance of the AEC Task Group repcrt in 1974. There has been no need for a change in eirher of these. AX’s approach. and iME has folloved th.: ROUX, has been tz vie.2 :his project as a prac:fcal probien in r: 3lOgiCal przcec:Lsn. 7.0: an engineering cask. Thus, the phi? osophy used is the philoszph:: associated with curren: radiation protection standards that are issued tc guile Federal agencies ir! :heir radiation. protection act ivitias. DOE cannot urfla:erally change the philosophy or chc basic nuaerical standards that have been derived thercfrx. I ! ._ as the level belov vhich soil cleanup vould not ba required. Yone oi :hese planning criteria have been changed or made more stringent. DG5 vill ;Ise the full value 2f Federal standards for individuals i:. t?e ?optia:l on to eva:*uate post-cleaxu? radiological conditions a: t‘xevetak Atoll. D&U objected to the Task Group approach in developing recommendatizs on :leanu:, criteria and developed rzommendations of their own. Their concern was that Lf cmse criteria vere set as lov for claacq of Enevetaic 80 :hose under consideration a precedent vould be %et that xay be difficult to meet elsevhere. As :o :he *kdefLnice quarantine of Islands, tc our X?ov?edge only 0r.e rslanc . Las ever been discussed i= this context. This is Kunit Island. i5:e.AEC Task Group cznsidera5 Runit a special case and made no rec3mmendatlons. for cleanup qecific co :hat island. The seLection sf the mechanin and site for disposal of :ontaminated debris acd so+ 1 vas zade bv 3&l on al-lice from :?_A. The AEC acqui- esced though ;i to the timk sf this Lecision ve Sad scrcnsly supported ocea:: dis-,osal. I-*-&__._I ; - XZ dose es:2nates 52r ?Larning cleaxp anl rchabiLi:arlzc have used averages, not “vors: region.” This item may refer to recent dose estimates developed by DSA s:aff for vhich ME and its ccrzrac:~rs :?ave ?ro.rided cozrxents. Cur present in:en: is to use island a-Jerages 12 rh? ecd-cf-cleanu; evaluatio:: of :S.e Enewerak er3ir2czte7.r althou& ve are :onsLderiq developren: of a :ompariscr. assassze~- ._ -%a-_. L will shov wLe_.. ixoact. XI dose esrizatcs azd recxze:- da-‘srs-- 1 ii restriccizns a-eA zot fol’-vedAU . T-a_ . __L_ c - 3.2: has xi zadc radislogi:i? cleanu? crireria 2oce strzge2r because of :he E?X ?r2;cset gui2elines. Sectf0r.s of the draft reczxendatiacs were prsvided by the Task GrDU? cz E?.l staff for :~zzzec:s and suggesciacs as the grzq’s repcrz gas developed. 2.4’s suqge stions were most :lel?ful. ‘-1.1 also ?attizi?aced Ln the :evfs’; Frc Item e - The statement that the Task Group’s radiological clean:? guidel- ‘-es considered only Pu-239, 2&O is incorrec:; The published scientific report* that provided :he key fnformacion relating con- centration of long-lived alpha radioactivityin soil to dose :o ~‘-211 contafrs the assumption that there vi11 be a distribution or mixt.ure of such alpha emmitters in the soil containing all those transuran- ium elements that vould be expected from a nuclear weapon detona;ion. The AEC report used the term plutonium or plutonium-239, 240 when it should have used the term transuraniun eienents. This Point vas clarifiedwith DNA before SOli removal began. Item f - A much greater intake of coconut (abcu: 10 times greater than used earlier) has appeared in a report prepared by ?iX staff. Cor-men:s from WE to DU have raised serious questions about the vc. Zit? of such an assumption. Ye are not aware of the status of the report and whether it is :o be pubiis’ned. Item g - The LO and 100 pCi/g criteria recommended for use in decisions on cleanup of contaminated soil at Enewetak ha-Je not be*n changed or made more stringent s ince the Task Gr>up report was issued in 197h. In the EIS, soii levels below SO pCi!gm vere judged not to require Cleanup. i%S is Still our recotrcendaticn. I: yas recommended in the EIS that soils having greater than S@c pCii gm should be cleaned up wherever these ievels =ere fc-nd. This is also still o*Ir recommendation. The value of LCC pCi/g is t3 5e used by 3SA in the cieanup of the Aomon crypt. Islands having sc:l concentrations in between these values (from LO to LOO pCi/gm) verc to be treated on a case-by-case basis. D:JX requested and receivei addi:iocal advice on how :o make these case-by-case decisions. They have not requested any further advice regarding soil Cieazxp criteria. S. Page 19 - DOE is commifred to perizm long-term rsciolagical foil-_=- up of Eccwetak residents and their environment including mnitcritg any efil uent from the disposai of contaminated debris ant soil on Wnit Island. This- does not include monitoring or inspec:ion cf :he ang 33 I I A'PE'IDI: 10. 11. APPEXDIY ‘ I I APPZXDIX I I less 10 years, 30 to years. Ve recognize this as one cf the most important difficult technical questions CC be addressed, and are working :o get the answer. iSe gnjebi pwpie were briefed in l?i4 and infomed that their island could cot be cleaned up so that they could retuz CO iive tfiere. This testriction was stated in the EIS. Follo~ 12. Tage 25 - We believe that E?A would bo- an apptopria:e organi:arion to provide guidance with regard to the possible ocean disposal of the radioacti7e debris at fsewetak. The EZ’A is develcping ocean disposal guidelines and has a related research and developnecc project. It 9, possible that our proposed ocean disposrl cccl’ be incorpora:ed io that research and development project. 35 Ai??EN3iX Ii EKLCSUFiE I BIKINI-EWiETAK SIMIIARITIES AEOUT SAPlE!!lXBER OF PEOPLE INVOLVED, NUCLEAR TESTS INSAKE GECGRAPHIC LOCATIONS, NUCLEARTESTS ABOUT THE SAKE TIliE PERIOD, W3iESTkSL4ND IN SOUTH AHD LICHTLY CONTAMINATED, L;IRGEAREAS SUBJECTED TO LAPlD CLEARItlG, M/UYBUNKERS AND CONTAPII~~ATED SCRAP, KGSTCCZONUT AiiD OTHER FOOD PLAfiTS ARE FYIISSING, FISHAND SHELLFISH HAVE LOW RADMACTIVITY, TER!ESTRIALFOODS.HAVE THE HIGHER LEVELS OF P&lWKTIVITY, * UGOCN5IATER HAS VERYLOGI RADIOACTIVITY LEVELS, DIETAtiD LIV!NG HABITS OF THE PEOPLE ARE ABOUT THESh?E, B?.SIiRADIATiON STANDARDS ARETHE SAME, A)?PENDIXII A??ENDI: r AT ENFta-ETAK UE!‘Y TEST COZDUCTED (!I0 hXXLEA.3XZLD). NuCL"%a CuTEaS c:iLxiz. A.XEASOF EIGE LEYZL PLWXi'GfA..I!~SOIL. ALMOST T'tJZCEAS !!.!JJYTESTS AS 313iNI (42/23) l CLEUi iWD BEZ2ZILIT~TION:;OT 'ET CO:iZ. 'PEOPLELIVZD IX '30 GZOZS, OK",IN SOGTE A.l4DONE 13 NCETZ CF i7tI.L. NXPA/EISSE~Ci?s3EXS. CCEJJ DBZ'ING LZGIS-2:::::. INCZUSE3 COBSE?i'i‘.:TIS:!I!7A??LICATIC'l OF RADIAT;OI;??.G"ECZI3:: SZ'.?!!?XXS. APPENDIX III APPENDIX III DEPARTMENT GF STATE Janxarv& 10, 1979 L3l.r. J. K. Fasick Director International Division U. S. General Accounting Office Washington, D. C. Dear .ti. Fasick: I am replying to your letter of November 29, i978, which forwarded copies of the draft report: "Observations on the 2roject t0 CieZnUp, Rehabilitate and Resettle Enewetak Atoll." The enclosed comments on this report were prepared by the Deputy Assistant Secretary for the Bureau of East Asian and Pacific Affairs. :L'eappreciate having had the opportunity to review and comment on the draft report. If I may be nf further assistance, I trust you will let me know. Sincerelv. Rog& 5. Feldman Deputy Assistant Secretary for Budget and Finance 3x losure : As stated APPENDIX III APPENDIX III GAO DRAFT RE?ORT "Observac;L,ons on the Project to Cleanup, Rehabilitate and Resettle Enewetak Atoll The Department of the Interior administers the Trust Territory of the 2acific Islands, including Enewetak Atoll. The State Department has not become directly involved in the cleanup projects for Bikini or Enewetak which are the joint responsibility of the Department of Defense, Energy and Interior. The State Department does, however, take an active ro:e in the political status negotiations with the IYicr0nesian.s. The issue of post- tzxsteeship liability and claims resulting from the US nuclear testing program has been raised in the status negotiations. Detailed provisions have not yet been discussed and it is impossible at this time to dete,?nine what degree of detail the US-Micronesian Compact of Free Association will contain on this subject. It is likely that the Marshall Islands representative at the negotiations will seek rather far-reaching assurances in this matter. The Department of State will take into account the recommendations contained in the GAO draft report in the status negotiations. Set-m-a--- 3eF,ct-,j Xssistsc= ______d 35