(2)

Materials must be of such a nature that only short term

localized effects would occur sOould the containers rupture.
(3)

Containers must pose no threat to navigation or fishing.

S/

In discussions with EPA, 8 August 1974,it quickly became apparent

that to dump low-level contaminated soil in the ocean, DNA would be required
to give assurances that the containers would have a life equal to 5 half lives
for Plutonium 239 - or 125,000 years, clearly an impossibility.

To meet the

remainder of EPA criteria, extensive oceanographic studies would also be
required that would add significant costs and time to the project.
This position was confirmed by an EPA letter Dr. Rowe to DOE, Dr. Biles,

17 May 1974”in which the general reluctance to initiate any ocean dumping
by EPA was expressed.

In discussions of various potential disposal techniques

the EPA favored the notion that contaminated material should be placed where
it could be observed and retrieved if necessary, rather than buried in an
irretrievable location.

Based on the expressed philosophy, a method using

the crater for disposal was proposed in the DEIS.~ Comments received from
Region IX EPA in their letter of 12 December 1974”stated "The choice of

crater entombment for disposal of contaminated soil appears to be the most
feasible alternative and provide some degree of retrievability.

The

fact that this is only a semi-permanent solution should be recognized.
Several other ..... option."

(Emphasis added).

In the EIS a full dis-

cussion is contained in para 5.4.3.2.3. which also provides some of the

&/

engineering details.

By implication in the EIS, the entire volume of

Select target paragraph3