Analysis of the permitting processes associated with exploration of Federal OCS leases. Final report. Volume II. Appendices Page: 147 of 282
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EXHIBIT 10 - (Continued)
5. The proposed modifications of NDPES permits will
inadequately protect ocean resources, since adequate bioassay
methods are not required. Methods utilized fail to require
tests on assemblages of plants in the area affected by discharge
and do not determine chronic and long-term impacts of such dis-
charges. Other specific requirements of 403 (c) (1) of the
Clean. Water Act and the Ocean Dumping Criteria of the Marine
Protection' Research and Sanctuaries Act will likewise be
neglected by use of inaeequate .ioassay test.
6. We call for the use of 40 CFR Part 227 ocean discharge
criteria in determining the impacts of exploratory well dis-
charges and-, if necessary, a requirement that drilling muds,
cuttings, formation water and at-her effluent-s be barged tb
certified dump sites.
7. Dumping of discharges should not he permitted u ntit
adequate bioassays are performed and alternate disposal sites
are investigated.
Suomitted by:
Date: Aoril 9, 1980
Michael David Cox, esq.
Environmental Defense Center
1005 Santa Barbara Street
Santa Barbara, California 93101
605-963-16::2
Representative for RequestorsB-102
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Analysis of the permitting processes associated with exploration of Federal OCS leases. Final report. Volume II. Appendices, report, November 1, 1980; United States. (https://digital.library.unt.edu/ark:/67531/metadc1184664/m1/147/: accessed July 16, 2024), University of North Texas Libraries, UNT Digital Library, https://digital.library.unt.edu; crediting UNT Libraries Government Documents Department.