- a \ \ February 28, 1975 Martin B. Biles, Director Division of Operational Safety : ; THRU: L. Joe Deal, Assistant Director for Health Protection, DOS DISCUSSION OF EPA INTERPRETATION AND APPLICATION OF ‘CURRENT U.S. OCEAN DUMPING LEGISLATION AND REGULATIONS During the past week, ERDA-OS staff have had opportunity to hear first hand how EPA staif are applying current domestic legislation related to dumping of radioactive contaminated materials into the ocean, These discussions took place within the context of unique circumstances of planning for cleanup of fnewetak Atoll, an acticn where DNA, DOI, and ERDA all have responsibilities. Enclosure ] is a Memo for the Record prepared by DNA staff of a meeting on this subject last Monday. This memoinmy view is a faithful review of the comments at the February 24 meeting. Enclosure lI is the recent guidance developed by LAZA for impiementation of the agreement reached through the Ccean Dumping Corvention of 19672 which we understand has been approved by the U.S. Enclosure lllis the current domestic legislation hereafter referred to as the "Act.'’ Enclosure IV is the EPA Regulations hereafter referred to as the "EPA Regs."' Enclosure Vis EFA cormment on the AEC draft ''Report by the AEC Task Group on Recommendations for Cleanup and Rehabilitation of Enewetak Atoll.'' Enclosure VI is AEC comments onthe DNA EIS for cleanup of Enewetsk, I believe this episode with EPA may be of far wider interest than just those of us who face the current dilemma of how to dispose of contaminated ecrap and 439PRy contaminated soil at Encwetak Atoll. At the outset of our discussions, EPA representatives arreed thet there were differences between the domestic and Internziional aie” ose. Rerulations, but quickly pointed out that the Internalienn! Pezuiations ailow any party to adopt more restrictive revuirements, The first point I wish to make is that the Act and particularly the EPA Fess. are not justi more restrictive, they are completely different; the; are hased onan entirely different policy and philosovhy and contuin elements not included and probably not intended by the Internation, Regulations. Orricr je SURNAME DaTs » Porm AEC-318 (Her, 9-53) AECM 0249 STU. 0; GON ERANMLUNT PRINTING OFFICE 1074-526.166