Martin B. Biles
8.
-4-
Enclosure VI shows the quantity of alpha wastes, assumed to
‘be 2391, dumped into the ocean during the last eight years
undor a prozram managed by the European Nuclear Energy
Agency.
Thus, the Interc tonal roticy is to allow ocean
dumping of limited quantities Gr rac:-Guctivity in a controlled
fashion and there is an agency to facilitate and coordinate
dumping by certain European nations.
The added features of the Act and EPA Rega., (compared to
International Regulations) which in our experience prohibits only
U.S. agencies from putting radioactivity into the ocean, are of
questionable value in protecting the ocean environment and are
of no wee in golving any waste Ciscosal protlems inthe U.S.
These
provisions are highly discriminatory agzinst the U.S. considering
thet other nations are dumping radioactive wastes into the occan.
Ocean dumping by other nations will presuincdly continue since
such actions are allowed under the International Reruletiens without
eo much ''rcd tape." Forccases such as clearup of“old radioactive
facilities and nuclear testing grounds, these resulations are in
conflict with our requirement to kcep exposures of people as low as
practicable. In this context, U.S. regulations have a negative benefit
for U.S. people.
As otated by Mr. Wastler in item 3c of Enclosure 1I".... if you have
a DEIS which stateg another feasible disposal method, it virtually
eliminates one of the requirements for an ocean dumping permit,
namely the lack of ak alternate disposal methed."' 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 including
locations and methods cf disvosal and land-based alternztives, (see
Sec. 102(3)(G) of Enclosure Hil),
The Act does not state (if so I cannot
find it) that the existence of some cther alternative virtually climinztes
the possibility of obtaining a permit.
This is an EPA requirement
additional to the Act that goes far cutsido the requirements of the <\ct.
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 weighcd against land-based altcinatives, "'
Thus, the existence of other options, unde: these regulations, does
not rule out obtaining an ocean dumping permit if ocean dumping is the
bect alternative. The International Rerulations require that participating
nations evaluate variouy alternatives and do what is practical and reasonat
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