447 



the parameters of the program, and what do you look for? Obvious- 

 ly, the first determination that I would think you would have to 

 make if the canisters were breached would be whether it would 

 jeopardize the food chain or violate the statute dealing with unrea- 

 sonably degrading or endangering public health — you have the 

 standards set forth in the statute. 



Mr. Mattson. I think that clearly EPA has to compare the ocean 

 dumping of these materials with their shallow land burial. Shallow 

 land burial doesn't guarantee isolation of these wastes from the 

 terrestrial food chain. It doesn't guarantee that the materials will 

 be there until they have decayed to innocuous levels. The history 

 in this country is replete with examples of materials that haven't 

 stayed confined to waste disposal areas, both high level and low 

 level. 



Mr. Hughes. Where will you find that particular standard in the 

 statute? 



Mr. Mattson. I'm sorry, sir? 



Mr. Hughes. Where do you find that particular standard in the 

 statute? 



Mr. Mattson. The statute says that before EPA can permit an 

 activity allowed under the statute — that is, before we could issue a 

 permit for low-level radioactive wastes — we have to find that it's 

 the preferable thing to do relative to other alternatives. Mr. Dyer 

 can dig up the citation and we can give you the number. 



Mr. Dyer. Yes; I have it. I think what Dr. Mattson cited earlier 

 was the basic CEQ established premise, that you would have to 

 consider ocean disposal relative to land-based alternatives. 



Mr. Hughes. I'm trying to find out where you find that. 



Mr. Dyer. Yes, I shall obtain the precise citation for you. 



Mr. Mattson. I'm reading from section 102 of the Ocean Dump- 

 ing Act — I'll read a couple of introductory sentences and then jump 

 down. It says: "The Administrator shall establish and apply crite- 

 ria for reviewing and evaluating such permit applications and in 

 establishing or revising such criteria shall consider, but not be 

 limited in his consideration, to the following:" It goes (a) through 

 (i). 



Paragraph (g) says: "Appropriate locations and methods of dis- 

 posal or recycling, including land-based alternatives, and the prob- 

 able impact of requiring use of such alternate locations or methods 

 on considerations affecting the public interest." 



Mr. Hughes. But the statute itself indicates that in determining 

 whether a permit program will be utilized, the Administrator will 

 determine whether such dumping will unreasonably degrade or 

 endanger the public health and welfare. 



Mr. Mattson. Yes, sir; that's another finding that must be made. 

 I'm not disagreeing with that. 



Mr. Hughes. In essence, what I'm trying to find out is what do 

 you feel are the parameters of your findings in determining wheth- 

 er or not to permit the dumping of low-level wastes? 



Mr. Mattson. Well, whether sites and canisters can be pre- 

 scribed that would still make the alternative viable, that would 

 assure no significant effect on the health of man or the marine 

 environment. These are the kind of tests we would apply. 



