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economic potentialities." 33 U.S.C. at §1412. Regulations and 

 criteria were published initially in 1973, with the most recent 

 substantive revisions thereto published in 1977. 40 C.F.R. Part 

 227. In addition to other criteria which tracks the statutory 

 guidelines, those regulations appropriately carry forward the CEQ 

 Report's recommendation that the oceans be considered a dumpsite 

 of last resort, requiring a finding by EPA prior to permit 

 approval that "there are no practicable alternative locations and 

 methods of disposal. . .available, .. .which have less adverse 

 environmental impact or risk to other parts of the environment 

 than ocean dumping." 40 C.F.R. at §227.16 (a) (2) . 

 A. Recent Ocean Dumping Amendments 

 As mentioned in our introductory comments, early this year 

 the Ocean Dumping Act was amended. Amendments to 33 U.S.C. 

 §1414, Public Law 97-424, 6 January 1983. Those amendments made 

 three beneficial changes to the Act in relation to ocean disposal 

 of radioactive wastes. First , there is a two-year moratorium 

 (until January 1985) on the approval of any permits, although 

 limited "research" dumping might be permitted. 33 U.S.C. 

 §1414 (h). Second , following the expiration of the moratorium any 

 permit application must be accompanied by a "Radioactive Material 

 Disposal Impact Assessment." 33 U.S.C. §1414(i)(l). That 

 assessment must address a variety of enumerated environmental and 

 economic issues, include determinations by affected coastal 

 states that the proposed action is consistent with approved 

 Coastal Zone Management Programs, and incorporate comments and 

 results of (1) consultations with state officials and (2) public 



