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pounds of waste each. They have never been tested in deep water; they have the 

 potential to rip as they are dumped off the barge; there is no evidence showing 

 they can withstand the forces of the deep ocean; and it is likely that their disposal 

 in the ocean would be illegal under international and domestic law. 

 10. There is no need to embark on this proposal of herculean and completely 

 unproven proportions. Contaminated sediments can be stored on site, in upland 

 facilities or treated. It is illegal to dump any other wastes in the ocean, with the 

 exception of clean dredged materials. If the dredged sediments are clean, there 

 are many beneficial reuse options, beach renourishment or safe disposal 

 alternatives available: they are a resource, not a waste. 



The Report acknowledges some of these very fundamental problems in its next-to-the-last 

 page. It acknowledges that the downside of the "Surface Emplacement" concept is that "the bags 

 are expected to drift apart as they fall through the water column," which presumably would 

 make it difficult to actually dump in the designated dumpsite. Earlier in the Report, it is noted 

 that the only experience with dumping bags of waste in the ocean has come from the Army 

 Corps of Engineers in water depths of less than 300 feet, which is less than 5 percent of the 

 depth of water discussed for deep ocean dumping. The susceptibility of bags to drift is raised. 

 Bag survivability on the ocean floor is also a complete unknown. The bags can also rip as they 

 exit the barge. And there aren't enough of them: currently, 700 are made a year and the 

 "Surface Emplacement" project would require seven times that. 



This entire concept pivots on the notion that wastes will be kept out of the marine 

 environment because they will be in bags. But almost nothing is known about these bags, 

 whether they can survive on the seafloor, whether they will land in the targeted dumpsite, 

 whether they will rip on their way out of the barge, even whether there will be enough of them 

 to sustain this new mini-industry. 



This concept also depends on current law being overturned. On the last page, the Report 

 notes that the Ocean Dumping Ban Act made it illegal to dump sewage sludge at sea. 

 Incinerator ash may contain contaminants that are prohibited from ocean dumping under the 

 international treaty called the London Convention. And the synthetic bags themselves could well 

 be illegal since the Lx>ndon Convention, the International Convention on the Prevention of 

 Pollution from Ships (MARPOL) and the Marine Protection, Research and Sanctuaries Act 

 (MPRSA) make it unlawful to dump persistent synthetics in the ocean. 



Why is an activity that is illegal, potentially very damaging to the environment, extremely 

 costly and entirely unproven being considered? 



Decontamination Technologies Are Further Developed Than Deep Ocean Dumping 

 Technologies 



Instead of sinking Federal dollars into developing ocean dumping techniques, the Federal 



