February 28, 1975
TERU:
LI. Joe Deal, Assistant Director
for Heslth Pretecticn, POS
DISCUSSION OF EPA INTERPRETATION AND APPLICATION OF
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CURRENT U.S. OCLAH DUMPING LEGISLATION AND REGULATIONS
During the past week, EROA-OS stafi have had opportunity to hear
first hand how MEA clati are applyins current demestic legislation
related to dumming of radioactive corinminatec matcrials into the
ecean. These dic cussions teak place within the context cf unique
circumatances ot Wlannins sor cleanup cf Enewetak Atoll, an action
where CiVA, DCI, and 2ADA all have responsibilities.
Enciesure lic a Memeofer the Record nrepared by DWA st-ff of a
sting on this eubject last Monday. This memo inrmy view isa
fwiihtul raview of the comments atthe.. eoruary at necting. En
e ilis the recent pridance deveioped by LALAfor impicmentation of Dia agresiment reacned throuch ine Ccean Dumping Cunvention
£1972 -chich we understand has been approved by tne U.S
oS. tUnclosure lilis the current comestic legislation hereatter referred
tocs the "Act."
Enclosure IVis the DPA Regulations hercafter
referved to as tae "ERA Recs," Enelosure Vis CPA comment on
the ALC arcitReyOrt by the ALC Task Group on Recommendations
for Clenrup end Pebubilitezion of Sneweiak atoll." Enclosure VI
is ALC comments onthe Dili EIS for clearun of Enewetak.
I
hellcve this epicode with [lui inay be of dar wider intercat than
just thoce of us who face the current cilemma of howto cisnase of
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At Gie outset of our Ciscussicns3, EPA representatives agreed that
there were differences betvrean the Comestic end International
Reevlstions, ut cuieniv neinted ont that the Intarnntional eg atatons
aliow Quy patty te acout more restricuve rasuitements. The first
point I wish te make is thet the Act and particularly the EFA Pers
are not just rnore restriciive, they are co
ompletely different; chey |
are based onan entirely difrerent roalicy and philosovhy and contain
clenents not included and probably not intended by the Intcriational
Rerulations.
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