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Mceting to Discuss Disposal Methods for Radiologically Contaminated
and Non-contaminated Materials - Enewetak Atoll Cleanup
~ EPA~ 24 Feb 75°.
Oe
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c. llr. Rowe asked Mr. Wastler, EPA to discuss the requirements involved
obtaining a permit for ocean dumping. Mr. Wastler said that while the

statutory act listed nine criteria for consideration in issuance of a permit,
they could be summarized as follows: (1) Establishment of a need to dump,
(2) The lack of an alternative means of disposal, (3) Definition of the

potential damage that could result to the marine environmentand effect of

the proposed dumping on other users'of the area. He said that a permit could
be granted only for an approved dumping site. To obtain approval for a
dumping site requires selection of a definite site, a survey of the dumping
', area including the benthic community, ocean currents and definition of the
monitoring process to be used while the dumping is carried out. He thought a min:
of at least 4 months would be required after receipt of a properly executed
application before final action could be expected from our request to EPA.

Involved in the process was the requirement for a public notice of 30 days
_and then a public hearing 30 days after expiration of the public notice, followe

~- fe

~~

by allowance of, another 30 days for the EPA hearing officer to reach a finding.
No assurances could be provided that the finding would not be adverse,
particularly if any controversy exists. He stated that if you have a DEIS
which states anqther feasible disposal method, it virtually eliminates one

-of the requirements for an ocean dumping permit, namely the lack of an
alternative disposal method. He was apparently supported by other EPA
representatives in this statement. se
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There was also a general discussion on the requirement for

containerization of the material to be ocean dumped and just what was meant

by the requirement that the container should hold the material in tact until

it was innocugqus.

This discussion discounted the impression we received last

__, August that there was a requirement for a containerization module
for 5 |

half lives of the contaminant.

���Instead he indicated that the material

should be containerized until it reached an innocuous state in
relation to the

environment in which it was placed.

The key here being whether or not

its
release from containers would have an adverse effect on
the surrounding eco-

System. Since the half life activity of plutonium is so
long (24,360 years),
it is apparent that the ecological system into.which
the release is made
en tee ne

has a dominant effect on this interrelat
ionship.

e. Mr. McCraw of ERDA next gave the ERDA position for ocean dumping.
He briefly reviewed ERDA's desire to make the contaminated material unavailable
to the food cycle of the returnees. . Since it has been agreed that radio-

activity in scrap metal is locked in its own matrix it appeared more likely
a permit for its deep ocean dumping could be granted. Mr. McCraw made the
case that no allow:nce had been made in the. computations of the dosage

projected for the returnees for an increase to be received from leakage from
the cememt-matrix of plutonium bearing soil into the lagoon and near ocean.
For this reason ERDA/AEC preferred ocean dumping. Mr. McCraw made the statement
that the lagoon was already heavily contaminated with plutonium and other

radioactive materials which was readily discernible in the heavier concentratior
found in outflow measurements as compared to those made of the inflow.

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