he awl, Martin B. Biles 8. Enclosure VI shows the quantity of alpha wastes, assumed to be 239Pu, dumped into the ocean during the last eight yeara under a program managed by the European Nuclear Energy Agency. Thus, the International policy is to allow ocean Gumping of limited quantities of radioactivity in a controlled fashion and there ia an agency to facilitate and coordinate dumping by certain European nations. The added features of the Act and EPA Regas., (compared to a U.S. agencies from putting radioactivity into the ocean, are of . walle om ks Caob et asta illaenae a Nae a a een International Regulations) which in our experience prohibits only questionable value in protecting the ocean environment and are of no use in solving any waste disposal problems inthe U.S. These provisions are highly discriminatory againstthe U.S. considering that other nations are dumping radioactive wastes into the ocean. Ocean dumping by otter nations will presumedly continue since such actions are allowed nese the International Regulations without 90 much "red tape.'' Forgcases such as cleanup of old radioactive facilities and nuclear testing grounds, these regulations are in conflict with our requirement to keep exposures of people as low as practicable. In this context, U.S. regulations have a negative benefit for U.S. people. _ As stated by Mr, Wastler in item 3c of Enclosure I'"'.... if you have a DEIS which states another feasible disposal method, it virtually eliminates one of the requirements for an ocean dumping permit, namely the lack of ai alternate dispasal method.'' This statement reveals probably the most serious difference of all between the Act and EPA Regs., and between EPA Regs. and International Regulations. The Act requires that the Administrator (of EPA) shall establish and apply criteria for reviewing and evaluating permit application includinz locations and methods of disposal andland-based alternatives, (see The Act does not state (if so I cannot the possibility of obtaining a permit. This is an EPA requirement — additional to the Act that goes far outside the requirements of the Act. ‘The International Regulations state that in the environmental assessment that is to be made, consideration is to be given to the "justification for the proposed dumping, when weighed against land-based alternatives. '' Thus, the existence of other options, under these regulations, does not rule out obtaining an ocean dumping permit if ocean dumpin?z ia the ane best alternative. The International Regulations require that participating _ mations evaluate various alternatives and do what is practical and reasonab! * i ce he te ke ht ei eeeee er eS Sec. 102(a)(G) of Enclosure Il). find it) that the existence of some other alternative virtually eliminates of