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that only carcinogens, etc. present as other than "trace contaminants" would be 
prohibited from being dumped. 
Addition of New Evaluation Factors to §102(a) (S4(1), p. 7). 
We strongly endorse the addition of evaluation factors requiring consideration of: 
dumping impacts on the camposition and vulnerability of exposed biological commmities; 
and the cumulative effects of a given dumping proposal in conjunction with other 
sources of contamination of the dumping area. 
Addition of Specific Site Study and Monitoring Requirements (§4(3), pp. 9-11). 
The incorporation of these provisions is highly desirable. (Several wording 
changes would be helpful, however). 
Processing Fees and Special Fees (§6(1), p. 14, lines 11-23). 
Internalizing the costs is highly desirable and long overdue. (It should be made 
clear, however, that the proceeds from collecting these fees should not revert to © 
General Revenues, but should be earmarked to defray the costs on which they were based). 
Moratorium on Dumping of Radioactive Wastes (§8(d), p. 18). 
We aassece the notion that authorization to ocean dump radioactive wastes—-suspended 
in the U. S. since at least 1970—should be withheld for a sufficient period to 
ensure that such wastes can satisfy the “findings” and "“policies'of the MPRSA, and 
to permit a comprehensive review of the radioactive waste ocean disposal plans of the 
Navy and the Department of Energy. 
Amendments to Title IT 
(a) Specifying some of the components of the long-range research and monitoring 
program under §202(a) is desirable. However, it is not clear that NOAA is best 
suited to develop a methodology for comparing the costs and benefits of ocean 
dumping with those of available alternatives. 
