75 



magni 



tude of the radioactive contaminatiion problems is even 



greater as the Russian Federation attempts to deal with the 

 decommissioning and dismantlement of ii:s vast nuclear submarine 

 fleet. These problems range from the processing of low- level 

 liquid radioactive waste to the transport and storage of spent 

 and damaged nuclear fuel from the submarine reactors. 



EPA recognizes that the Arctic is a fragile environment and 

 that the impact of releases of radioactive and associated 

 hazardous materials in this region may have unknown adverse 

 consequences to the unique ecosystems 'involved. It is the 

 potential for biological change that iJs of most concern to 

 people. Therefore, a careful scientific approach must be used 



when considering the release of radioactive and associateid 



J 

 hazardous contaminants into these Arctic seas. Since there are 



multiple sources of contaminants to the Arctic, we advocate a 



comparative approach to assessing risk so that the most important 



sources can be mitigated as quickly as possible. 



ync 



You have asked us for a -short synopsis of past U.S. dumping 

 activity and current policy. The U.s! phased out all ocean 

 dumping of radioactive materials by 1970. In that year, the 

 Council on Environmental Quality issued a recommendation (Ocean 

 Dumping: A National Policy) calling for cessation of any future 

 ocean dumping of radioactive materials by the United States . In 

 1972, Congress enacted the Marine Protection, Research and 



