654 



When we learned of the Department of Energy (DOE) interest in 

 testing the specific behavior of FUSRAP soils in the MERL tanks, we 

 decided that a cooperative study, with cost-sharing, could provide both 

 agencies with data for their respective purposes. Since the source 

 term had already been carefully analyzed by DOE, EPA felt that FUSRAP 

 waste would be suitable for assessing behavior of low-level 

 radioactivity in the marine environment. 



The fact that DOE may not participate does not change our Agency's 

 view that the MERL study, such as the one we designed, would be useful 

 in developing our permit evaluation framework. It does, however, force 

 us to reexamine tne study design in light of more limited funding for 

 this year, or to consider the possibility of postponing the study for 

 one year and funding the current scope of work in the next Fiscal Year 

 or to look for some other funding mechanisms. Initiation and/or 

 completion of the project may be delayed to some extent, which we are 

 still in the process of evaluating. 



3. Does EPA consider that its present monitoring and survey studies 

 for radioactive waste disposal at sea will provide sufficient infor- 

 mation to determine whether the resumption of ocean dumping will pose a 

 threat to health and the marine environment? 



ANSWER 



The information derived from EPA surveys of old U.S. dumpsites is 

 only one source of data which EPA would consider in determining whether 

 tne U.S. should resume ocean disposal of radioactive materials. Although 

 EPA's surveys have indicated that past U.S. disposals have not. resulted 

 in harm to either the marine environment or human health, EPA would not 

 allow future disposals to be carried out as they were in the past. The 

 Ocean Dumping Act of 1972, and amendments of 1983, EPA Ocean Dumping 

 Regulations of 1977, and London Dumping Convention criteria adopted in 

 1978 ail impose more restrictive requirements. In particular, the 1983 

 amendments require that a disposal permit applicant prepare a 

 Radioactive Material Disposal Impact Assessment that establishes the 

 safety of any proposed ocean disposal for the particular wastes at a 

 particular ocean site. Furthermore, an applicant must demonstrate the 

 need for -ocean disposal in contrast to otner disposal options. 



4. Does EPA see any problems with the "de minimus criterion" being 

 developed as part of the IAEA proposal for reclassifying radioactive 

 waste? What modifications would EPA see as necessary and are there any 

 areas of specific concern that EPA would want addressed to assure that 

 the definition is consistent with the requirements under domestic law, 

 sucn as the Ocean Dumping Act? 



