February 28, 1975 TERU: LI. Joe Deal, Assistant Director for Heslth Pretecticn, POS DISCUSSION OF EPA INTERPRETATION AND APPLICATION OF | 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 . . cart sttnated ccrcp se atid 238* wn “3 Coit te itga:unted geil ab Denevata kk o.wotl, 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. Orrice i= | vera C ye . Form APG-318 Chew, 9-$3) ALOT 0249 - reem * Re, ae futon ny . . . . es errr YY ul, GUVERRMLUNY PRINTING CFFICR oF 4-026.100 wom os ee b, tacabe sine ’ ae. : - oy 7 aimee "s ~ ate rote : mei ed woe . tee i mo hg ros ae|. . ‘< a ee : a eer we, . fr v7 rer Tae: *. e rate ey + ‘ where ny a - oe rare - > , wewtst ‘ Vy 5 On