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