343 



In 1973, pursuant to the Ocean Dumping Act, EPA issued broad 

 policy guidance in the form of regulations (40 CFR, chapter I, 

 subchapter H, part 227) regarding sea disposal of low level radioac- 

 tive waste. The basic requirements in those regulations were isola- 

 tion and containment of the radioactive isotopes to prevent their 

 direct dispersion and dilution in ocean waters. The regulations also 

 required that the containment system function until the radio- 

 decay of the waste to innocuous levels. These same requirements 

 were contained in EPA's revised regulations in 1977. These require- 

 ments are intended to reduce the risk to man and the marine 

 environment from any future ocean disposal practice. Although 

 special containers, such as steel drums with concrete caps, were 

 used in the earlier U.S. sea disposal operations, there was neither a 

 requirement nor an expectation that the material would remain in 

 the drums. The material was expected to be released eventually as 

 the drums and the concrete within them deteriorated. 



In 1972 the international convention on the prevention of marine 

 pollution by dumping of wastes and other matter was developed. 

 This is the so-called London Dumping Convention. It was ratified 

 by the United States in 1974, and it came into force in 1975. It now 

 has been ratified by 32 nations with accessions by another 14 

 nations. This convention provided for the first international control 

 over sea disposal of radioactive waste. In the convention the Inter- 

 national Atomic Energy Agency is designated as the responsible 

 body for developing the specific technical requirements and defini- 

 tions. Within the text of this convention there is a specific prohibi- 

 tion on the sea disposal of high-level radioactive waste or other 

 high-level radioactive matter, as these terms are defined by the 

 International Atomic Energy Agency. 



HIGH-LEVEL RADIOACTIVE WASTE DISPOSAL IN THE OCEANS 



You have asked us to consider the question of disposing of high- 

 level radioactive waste in the ocean — be it on or in the sea floor. It 

 is EPA's opinion that use of the ocean for the disposal of high-level 

 radioactive waste is currently prohibited, both under the proscribed 

 activities of the Ocean Dumping Act— Public Law 92-532— and the 

 dictates of the London Dumping Convention. With your permission, 

 I would like to submit for the record copies of internal EPA docu- 

 ments describing the basis for our opinions on sea disposal of high- 

 level waste. 



Mr. Studds. Fine. 



They will be placed in the record. 



[The documents referred to follow:] 



