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without the benefit of judicial review. One can only hope 
that, based upon this position, EPA will not object to the 
proposal to amend the Ocean Dumping Law to incorporate within 
the body of the Act the Convention's prohibition against 
dumping materials containing "black list" (Annex I) constituents 
as other than "trace contaminants." Such an amendment would 
serve only to enhance EPA's "authority to assure that [its] 
legal obligations in this area are fulfilled." 
Effect of the Draft AMICAMCRNECIE 
The draft amendments would refine the current statutory 
approach, by creating four categories of material proposed for 
ocean dumping: 
1) Material which does not degrade the marine environment, 
which can be freely ocean-dumped. 
2) Material which degrades but lacks "prudent and 
Sonaiintiae alternatives, which can be ocean-dumped under "interim 
permits" and somewhat more restrictive dumping conditions. 
3) Material which “unreasonably degrades" the marine 
environment, and, therefore, cannot be ocean-dumped, because 
it both degrades the ocean and has recourse to "prudent and 
feasible" disposal (or reuse) alternatives. 
4) Material, which because of its high content of highly 
toxic and persistent toxic chemicals, is absolutely prohibited 
from being ocean-dumped (such material is currently subject to 
similar prohibitions under the LDC). 
In so doing, the draft amendments, in our view, take a 
logical and moderate middle-ground approach somewhere in between 
