weighing 300-400 lbs would be essential, both at the University and at the burial site. An increase in staffing would also be necessary. 

I would consider the use of pit liners to be an unjustifiable expense (approximately $450 per pit). N.R.C. regulations governing the commercial disposal of radio-active waste (Part 61, July 1981) do not require or recommend pit liners. 

While the decision on how far it is necessary to go to placate the EPA must be based on what is best for the University as a whole, I would again point out that the radioactive waste disposal program is sound, and that the proposed changes cannot be implemented without a substantial increase in costs. It must also be borne in mind that these costs are substantially less than those associated with shipping radioactive waste out of state.” (20) 

       The other problem developed as a result of the EPA’s mandate to test groundwater. A March 16,1983 correspondence to Martha Anderson, UA Dept. of Risk Management, from the Arizona Dept. of Health Services states:
 

“As we discussed in our phone conversation of March 11, the compliance material received on March 7, 1983 regarding groundwater monitoring for the Page Ranch Facility still does not address the Federal (40 CFR Part 265 Subpart F) and State (ACRR R9-8-1821.A.2) interim status requirements for either the installation of a groundwater monitoring system or a waiver demonstration. 

In the past we have discussed the need to address groundwater monitoring at Page Ranch on a number of occasions. To the best of my recollection, during those discussions I stressed the point that the monitoring requirements were already in effect, never implying they were in any way contingent upon permit issuance. 

The letter you refer to from M. Wilson of EPA, Region IX (dated December 13,1982) is an overview of some of the effects the new land disposal regulations in 40 CFR Part 264 will have on hazardous waste disposal facilities in operation after January 26, 1983. His