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4,

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Diifeorent apnres ches are inherent in the domestic and international repulations: —
a.

The Act eppiicd by EPA requires containment of con4ayminated mterial after it reaches the ocean Slecr such that

levels outcide tho container are "innocuoug,'' The term
imnocnous in uewhere detined in ony numerical wayor
othowwise. JA will apparently hold to itself the determini:tion of whatis innocuous for a ‘sarticular cet of
circumstances.
earlier.

b.

This £3 one indeterminate mentioned

The International Regulations require that packaced wastes
reach the ocean bottom intact. Practical means are to
be used to put the deoris ina relatively insolubie form
or to place it ina
relatively insoluble matrix by designins
contoinmen: to retain the materi2i ror an unsecified
pericd, or te velect an area with characterisiies that

facilitate retention in the site vicinity.
5.

The Act and EPA Rega, provide that a nermit may he granted

by OPA citer the request for a permit has survived a “Vhearing"
and open debate where any person mav aspear whether or not
represented by ceunsel or any other authorized representative.

The Administrator of EPA is mzde the final judre of resuits

from the Mearinz. How he will do this is not indicated. (Even
the provisions of NEPA, related to a Hearing on an Onviron-

mental Impact Siatement, do not require this, )
6.

The International Reculations reauire no public Heeving

ccnures moris there a requirement to scek approval from any
other nat.on' B revossentatives. tfem C.1.2 of Ann:paceI
vittes, “Lt would be predentwJwor vhe Spare rrinte nation

authoritics to cuihorize dumping at the lewest rate whichis
reasonably practicotle, having remard to the development of
applications or muciear eneryy. "

7.

Dr. Rowe of EPA states in Enclosure V that "The U.S. has

had a national poiicy of no ocean dumping of radioactive
wastes since 1970." Te staten further that "it was surely the
intent of Lh 9e-O27 and the Brus rermuiations to rigidly control
or even to prohibit such dumping. Thus, it appears thst EPA

etafi believe thet itis U.3. coties to probibit such Comping.
he *

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