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HPPOS-271 PDR-9306100048

Technical Assistance Request, Disposal of Liquid Waste into Arctic Ocean

See the memorandum from J. E. Glenn to R. R. Bellamy dated June 25, 1991. This memo was written in response to the May 28, 1991 letter (Enclosure 1) from R. F. Rivkin, University of Maryland, Center for Environmental and Estuarine Studies, which was sent to NMSS by Region 1 as a TAR. As indicated in Mr. Rivkin’s letter, the National Science Foundation is sponsoring a research project involving the use of carbon-14 (C-14) and tritium (H-3). This project will take place in the Arctic Ocean during a research cruise from Murmansk, USSR, to Nome, Alaska, aboard a Soviet icebreaker, Sovetskiy Soyuz, from July 27 to August 16, 1991. Mr. Rivkin is seeking permission to dispose of about 10 millicuries of H-3 and 40 millicuries of C-14 in the Arctic Ocean.

Enclosure 1 states: “… the use of the radioisotopes will be to determine the rates of carbon incorporation of phytoplankton assemblages, the rates of bacterial production and the ingestion of bacteria and phytoplankton by microzooplankton in the Arctic Ocean. Briefly, either NaH14CO3 or methyl, 3H-thymidine (3H-TdR) will be added to seawater samples in glass or polycarbonate bottles and after an appropriate incubation interval, the particulate material will be collected onto a filter pad. The filter is retained and returned to the investigators home institution for further analysis. The seawater which passes through the filters contains the dissolved NaH14CO3 or 3H-TdR which was not incorporated by the microbial organisms.” And, “If this were a “normal” research cruise aboard the UNOLS fleet (i.e. the research vessels operated by U.S. universities), the liquid waste (in the filtered seawater) would be contained and returned to our university (in Maryland) for disposal. Unfortunately this will not be possible during this cruise. The port of debarkation is Nome, Alaska, which totally lacks rail and road service to the continental United States. The only way to retrograde the liquid waste would be by air which represents a significant safety hazard.”

By memorandum dated June 5, 1991 (Enclosure 2), NMSS asked the Office of the General Counsel (OGC) for guidance in responding to Mr. Rivkin. OGC’s June 20, 1991 memorandum is Enclosure 3. In summary, OGC indicates:

1. The Soviet icebreaker, a nuclear powered ship, cannot debark at Nome, Alaska, and cannot enter the territorial waters of the United States.

2. The NRC does not have jurisdiction over the proposed discharges of radioactive material into international waters. OGC suggests that Mr. Rivkin contact the State Department to learn if there are applicable international agreements or conventions governing such discharges. OGC also suggests that Mr. Rivkin discuss the proposed discharges with his Soviet colleagues.

Regulatory references: 10 CFR 20.2002

Subject codes: 9.0, 12.9, 12.13

Applicability: Byproduct Material