planning and Programming
ocean d umping.
97
ium which had
EPA pointed outthat the amountofpluton
g its waters was
been deposited in the lagoon and was circulatin in
crater.!53.154 In
, pably much greater than any that might leak from the
than there was
on
lago
the
nt of fallout in
ae
act, there was a far greater amou
far greater area than
ft on the islands to be cleaned up. The lagoon hada
into the
he islands, and material from the islands tended to be washed
lagoon.
EPA described the measures necessary to obtain a permit in the unlikely
other
event the plutonium contamination could be considered something
than “material in any form produced for radiological warfare purposes.”
The criteria for issuance of a permit were summarized as: (1)
c
establishment of a need to dump; (2) lack of an alternative means of
disposal, (3) definition of the potential damage that could result to the
marine environment, and (4) the effect of the proposed dumping on other
users of the area. Permits could be granted only for an approved dumpsite.
Obtaining approval for a dumpingsite required selection of a definite site,
a survey of the dumpingarea (including the benthic community) and the
ocean currents, and definition of the monitoring process to be used while
the dumping is carried out. A minimum of 4 months would be required
after receipt of a properly executed application beforefinal action could be
expected from a request to EPA. Involved in the process was the
requirement for a public notice of 30 days and then a public hearing 30
days after publication of the public notice, followed by allowance of
another 30 days for the EPA hearing officer to reach a finding. No
assurances could be provided that the finding would not be adverse,
particularly if any controversy existed. If the DEIS identified another
feasible disposal method, it would virtually eliminate one of the
requirements for an ocean-dumping permit, namely the lack of an
alternative disposal method.
The ERDArepresentative contended that EPA was overly conservative
in applying the United States ocean-dumping law, since the International
Ocean-Dumping Agreement would permit other countries to dump quite
large amounts of long-lived alpha contamination. EPA countered that the
United States law, which predated the international agreement, was based
on the philosophy of preventing further pollution rather than facilitating
cleanup and disposal of radiological contamination resulting from a past
event. Public laws and EPA regulations did not envision a disposal effort of
the magnitude of the Enewetak radiological cleanup and provided no
solution to the problem.
ERDArepresentatives responded that, while ERDA had several test
sites which someday must be decontaminated, ERDA hadnointention of
adopting ocean dumping for those wastes. However, there was
considerable concern that, if crater containment was used, ERDA would