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RE: GLIN==> Dry cargo discharges to the Great Lakes



Looking through the discussions on this issue and the documentation Dave
Reid provided, it occurs to me that the one thing that seems to have not
been much discussed, at least looking from the point of view of a
regulator, is that of quantity.  I didn't see any strict definition of a
quantitative limit in order to qualify under the policy, or of what are
the quantitative norms.  What quantities are we talking about, and is
there anything in the policy that limits those quantities, either per
the type of material, or on a per vessel basis, or from a mass loading
standpoint?  Does a permissive "deck sweepings" policy make for a
generous loophole so that it can be employed as a way of disposing of
waste bulk materials including perhaps lots that were deemed
unacceptable for off-loading at their intended destination due to
damage, contamination, or whatever?  Invariably, if a loophole can be
exploited, it will be exploited.

Robert Beltran
United States Environmental Protection Agency
OPA/Software Development Section (P-19J)
77 West Jackson Boulevard
Chicago, IL 60604
Ph: 312-353-0826
Fax: 312-353-3433
beltran.robert@epa.gov
www.epa.gov/seahome


The measure of a civilization is the extent to which it protects its
weak from the excesses of the strong. - Anon.

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