Martin B. Biles -2~ The practical side of the Act and EPA Regs. ia that they prohibit any U.S. agency or entity from dumping any radioactive debris into the ocean. This ie accomplished by use of certain barriers end indeterrminates that must be faced by amrone who considers ocean dumping as one of several possible dicposal aiternatives for radioactive debris. Implementation of this lecislation appears to ee ee ee place EPA staff in the position that they prefer and recommend land burial of ©39Pu debris even with the certainty of future failure of containment with release of material into the surfaceenvironmert. and the possibility of some exposure of the Enewetak people.. Land burial, recommended by EPA, is seen by them as only a temporary solution. This is quite different from theiy usual role of conserva- a nec ee ee 0 el ee ce ee ere tism in applying regulations where exposures of peorle are concerned, and their strict adherence and support of the lowest practicable concept. | I believe that the EPA application of current domestic ocean dumping regulations relative to disposal of contaminated debris of Enewetak, is a classic cxample of cases where concerns fora particular part of the environment ere in direct conflict with concerns for minimizing radiation exposures of a particular group of people. I can cite several ‘examples in the discussions of the past several days to support the statements above: 1. EPA staff did not even want to talk about International Regulations or the recent new guidance from IAEA (Enclosure Il). 2. The fact that disposal of contaminated debris and soil from the islands (an action yielding great benefit to Enewetak people) would be only a small contribution to similar material already on the nearby ocezn bottom trorn past nuclear tests, is not a consideration according to EFA staff. 3. ‘The fact that the current ctate of certain islands at Enewetak Atoll is now a Ead situation frorn a radiological viewpoint (the islend of Runitis quarantined) needire early remecdial action, is not a considcration according tothe Act. TIPA etaff agreed that the Act was not develoved with the Lacwetak situationin mind. (This in my view, is a very sericus mctter since it also means that dumping radioactivity contaminated material into the ocean cannot even be considered - because of the nced for extensive stidies, hearings, etc., that would take several yeara - in the face of a desperate situstion auch as could eccur with accidental release of radioactivity into man's environment. ) OFFICE SURNAME Pe DATE Forw AFC-315 (Rev. 9-53) AECAL 0240 Wo. 8. GOVERNMENT PRINTING OPFICE: 1074.586-1e8