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of over $5 million in FY 1980. The program's funding has 

 increased to $6.9 million for FY 1981 and the projected budget 

 request for the next several years increases substantially 

 (FY' 82 ($13.6 million); FY' 83 ($20 million); FY" 84 (S22 million); 

 FY' 85 ($32 million); FY' 86 ($32 million)). The SDP has been 

 incorporated into DQE's National VJaste Terminal Storage Program, 

 treating seabed emplacement as another one of the geologic 

 disposal options under review. 



SDP officials also participate in an international forum, 

 the Seabed Working Group, sponsored by the Organization for Economic 

 Cooperation and Development's ("OECD") Nuclear Energy Agency ("NEA"). 

 Six member countries of the Seabed Working Group, along with 

 other observer nations, meet annually to exchange information on 

 each country's efforts in the sub-seabed emplacement area. 



The infusion of significant sums of money into the SDP 

 raises several concerns about its current structure and 

 activities. It is questionable whether sufficient cost and 

 environmental comparisons of land versus ocean options have been 

 made. Annex VI to the London Dumping Convention requires 

 contracting parties to consider the "practical availability 

 of alternative land-based methods of ... disposal" when 

 establishing criteria governing the issuance of permits for 

 dumping low- level radioactive wastes. Moreover, NRC regulations 

 concerning disposal of low-level radioactive wastes (10 C.F.R. 

 §20.302 (c)) state that "[t]he Commission will not approve a 

 license for disposal of ... material at sea unless the applicant 

 shows that sea disposal offers less harm to man or the environment 



