655 



ANSWER 



The IAEA effort Co define de minimis quantities of radioactive 

 materials is based on the recognition that all materials contain some 

 amount of radioactivity, either from naturally-occurring radionuclides, 

 or fallout from nuclear weapons testing. Consequently, there is 

 technically no such thing as a "nonradioactive" material. In the real 

 world, however, there are a variety of materials whose inherent 

 radioactivity is extremely low and which are traditionally dealt with 

 as "nonradioactive" materials. These include dredge materials, sewage 

 sluage, construction debris, and agricultural wastes, as examples. It 

 is not the intention of the London Dumping Convention to require that 

 all materials be regulated as radioactive materials. So the question 

 for IAEA to resolve is wnere to establish a level of radioactivity that 

 will distinguish between traditional "nonradioactive" materials and 

 those wnich shoula be regulated as a low-level radioactive waste. 



The main limitation on the proposed IAEA de minimis criterion is 

 Chat it is based on a radiation dose rate limit (one millirem/year) 

 that requires the use of an oceanographic model to determine the 

 quantity of radioacCive material which would correspond to the dose 

 limit. Such models would have to show that radionuclides from the 

 de minimis waste would not find their way from the ocean back to man by 

 seafoods or other means whicn result in exceeding the dose limit. If 

 the IAEA de minimis criterion was to be applied in the U.S., EPA would 

 need to be assured of the adequacy of the models for verifying 

 compliance with the dose limitation. 



As far as the matter of consistency with domestic law, neither the 

 Ocean Dumping Act nor EPA Ocean Dumping Regulations presently provide 

 any guidance that distinguishes radioactive and "nonradioactive" 

 materials. Such distinctions are now made on the basis of what is 

 customarily or traditionally considered "nonradioactive" in relation to 

 the source of the wastes. For example, waste material associated with 

 nuclear processes are normally considered radioactive. Conversely, 

 ordinary dredge materials or sewage sludge would not normally be 

 considered radioactive. Therefore, the IAEA de minimis criterion could 

 De nelpful to EPA as a quantitative basis for making sucn distinctions 

 in the evaluation of ocean disposal permit applications under U.S. law. 



