487 



Absence of such program segregation would hinder and could 

 hinder accountability and review prior to commitment of addition- 

 al money that might be unwarranted research and development. 



Another concern involves the systematic information exchange 

 within the United States which we believe needs to be strength- 

 ened in order to help coordinate the activities of the various agen- 

 cies. Though DOE is currently formulating a memo of understand- 

 ing with NOAA and with EPA, outlining their interrelationship of 

 their seabed emplacement work there is no systematic consultation 

 with or dissemination of information to other interested or affected 

 agencies and outside groups — outside groups being peer review by 

 scientists and the public, to the extent we believe it is needed. 



One example I have listed on page 10 of my prepared testimony 

 of this lack of coordination involves technoloqy transfers for pack- 

 aging. 



Another concern involves interagency coordination. We believe 

 that NOAA rather than DOE should be given the lead agency role 

 for coordinating various non-regulatory ocean disposal program ac- 

 tivities. This ties in to Public Law 95-273 which gives NOAA the 

 lead agency role for monitoring research and development. To date, 

 NOAA's involvement in seabed emplacement issues has been limit- 

 ed, as Bud Walsh indicated, and they have a mandate to look into 

 six different issue areas. We believe it is critical that they be given 

 the staff capability and resources to perform the kind of lead 

 agency coordination role that I think properly should be housed 

 within that agency. 



Another concern involves the perceived lack of communication 

 and oversight in the seabed disposal area in international discus- 

 sions. We think it would be appropriate to have some more regular 

 interagency consultation than now exists on the seabed working 

 group issues that have arisen and will continue to arise as future 

 meetings are held. 



Finally, as to high-level concerns, the public interest organiza- 

 tions believe that an advisory committee on seabed emplacement 

 should be established which would include participation of all these 

 administrative agencies involved, the executive branch involve- 

 ment, the particular CEQ, peer review by scientists, and outside 

 representation by concerned public advocates. A public advisory 

 committee would contribute toward assuring built-in neutrality, 

 alleviating potential redundancy, coordinating efforts, personnel 

 and facilities, and assessing and formulating U.S. policy on this 

 issue. 



I think if I had to choose one of these concerns in the high-level 

 area as being the most important, it would be this one. Chairman 

 Studds, the need to set up a mechanism like this to have some 

 outside involvement, with a program that — I don't want to sound 

 too critical, but I just think it's a program that needs the kind of 

 accountability that hearings such as this provide and that an advi- 

 sory committee such as I have recommended could assist in provid- 

 ing. 



Turning to low-level radioactive waste, which I recognize is not 

 the primary focus of this hearing, but there has been considerable 

 discussion of, in part because of Congressman Anderson's concern 

 about monitoring off the California coast, in my prepared testimo- 



