Martin B. Biles
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Different approaches are inherent in the domestic and international regulations:
a.
The Act applied by EPA requires containment of con-
tarninated material after it reaches the ocean floor such that
levels outside the container are "innocuous,"' The term
innocuous in nowhere defined in any numerical way or
otherwise. EPA will apparently hoid to itself the determination of what is innocuous fora particular set of
circumstances. This 3 one indeterminate mentioned
earler.
b.
The International Regulations require that packaged wastes
reach the ocean bottom intact. Practical means are to
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be used to put the debris ina relatively insoluble form
or to place it in a relatively inacluble matrix by designing
containment to retain the material for an unspecified
period, or ta select an area with characteristics that
facilitate retention in the site vicinity.
5.
The Act and EPA Regs. provide that a permit may be granted
by EPA after the request for a permit has survived a “hearing"'
and open debate where any person may appear whether or not
represented bycounsel or any other authorized representative.
The Administrator of EPA is made the final judge of results
from the Hearing. How he will do this is not indicated. (Even
the pravisions of NEPA, related to a Hearing on an Environ-
mental Impact Statement, do not require this. )
6.
The International Regulations require no public Hearing pro-
cedures nor is there a requirement to seek approval from any
other nation's representatives.
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Itern C.1.2 of Appendix IZ
states, "It would be prudent for the appropriate national
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authorities to authorize dumping at the lowest rate which is
reasonably practicable, having regard to the development of
applications of nuclear energy. "'
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Dr. Rowe of EPA states in Enclosure V that ''The U.S. has
had a national policy of no ocean dumping of radioactive
wastes since 1970.'' He states further that "it was surely the
intent of PL 92-532 and the EPA regulations to rigidly control
or even to prohibit such dumping. Thus, it appears that EPA
staff believe that itis U.S. policy to prohibit such dumping.
OFFIC!»
SURNAM L p>
CATC }
Form AEC-318 (Rev. 9-53) AECM 0240
Ww U. 8, GOVERNMENT PRINTING OFFICE! 1074-526-168