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by all the affected agencies and by the U.S. Congress, should be 

 made as to whether it is appropriate or feasible to give such serious 

 consideration to the use of the oceans as a low-level disposal 

 medium. At a minimum, our international obligations regarding 

 radioactive waste should be reflected in the general dumping regu- 

 lations that EPA intends to issue next year, since we have already 

 committed ourselves to those requirements. 



Another area of concern is the monitoring of past dumpsites. We 

 would encourage EPA and NOAA in the very near future to reach 

 adequate understandings concerning future monitoring activities. 

 The specific arrangements could be set forth in a memorandum of 

 understanding, but that would need to include specific site monitor- 

 ing. Absent an adequate MOU, prepared, we believe, within the 

 next several weeks at most, monitoring should be statutorily re- 

 quired. In that vein, we could well agree with the kind of provi- 

 sions set forth in Congressman Anderson's bill, or something simi- 

 lar. I'm not necessarily certain that NOAA is the appropriate place 

 to house it. It may be more of a mixed relationship between NOAA 

 and EPA than what is set forth in the bill. 



As a final recommendation, the public interest organizations 

 believe that the current Ocean Dumping Coordinating Committee 

 and the Ocean Dumping Advisory Committee, which address inter- 

 national and domestic concerns respectively, need to be strength- 

 ened. 



One point the Farallon Islands hearings made painfully apparent 

 was the effect that lack of coordination and reluctance to take on 

 responsibility by and among Federal agencies have had in creating 

 delays and in contributing to public concerns. 



An advisory committee should be created, an advisory committee 

 that contains the elements I suggested with respect to high-level 

 should be set up. It should be much stronger than what now exists, 

 and it should include all affected administrative agencies, peer 

 review by outside scientists and members of the concerned public. 



Moreover, the systematic exchange of information amongst gov- 

 ernment agencies and the public can only benefit the process that 

 creates such an entity. The need for better cooperation of the 

 Department of Defense was a major recurring theme at the Faral- 

 lon Islands hearings. If you had such an advisory structure that 

 brought them in as a participant, hopefully you would bring out of 

 them a little more of the information we somehow have had trou- 

 ble getting to date involving their activities and their proposed 

 research. 



An article in the Boston Globe earlier this year talked about 

 several million dollars of research being done by the Navy with 

 respect to low-level waste research. I think other agencies could 

 clearly benefit by that information to the extent it's not classified. 

 In my opinion, most of it should not be treated as classified. 



In conclusion, national policies that determine the manner in 

 which we seek to preserve, protect, and utilize our vital marine 

 resources must be rationally advanced, subjected to continuing and 

 rigorous public review, and based on definitive environmental and 

 technical studies that incorporate support activities on land. Until 

 all these concerns have been met, there should be no serious 



