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The Department of the Army, on behalf of the Depart-— 
ment of Defense, also opposes section 3(4) of the bill 
which singles out low-level radioactive waste for unique 
and highly restrictive treatment. Specifically, the bill 
arbitrarily establishes a two-year moratorium on disvosal 
of low-level radioactive waste in the ocean. The Depart-— 
ment of the Army is concerned that the two year moreto-—- 
rium on dumoing of low-level radioactive waste in section 
3(4) would prohibit or interfere with the dumping of 
dredged material which may be contaminated by incidental 
quantities of radioactive material. Such dredged material 
poses no radiation threat to the environment. Unneces-— 
sarily strict regulatory treatment of this material could 
result in a total shutdown of important projects. We 
understand from the Committee Revort of the Committee on 
Merchant Marine and Fisheries that this is not intended. 
However, because the language contained in the bill could 
be so interpreted we are opposed to its inclusion in the 
Joaslelee 
Also, the proposed moratorium may ultimately inter- 
fere with the vlans of the Department of the Navy to 
disvose of defueled, decommissioned nuclear submarines. 
Although the specific provision in H.R. 6113 would have 
no inmaediate effect on efforts to evaluate and select an 
acceptable method for submarine disposal, it would set 
an undesirable precedent and may lead to pressure at the 
end of the two year period to continue the ban into the 
future. If, as a result of the evaluations currently 
being performed by the Navy in compliance with the 
National Environmental Policy Act (NEPA), the Navy should 
determine that it is environmentally acceptable and pref- 
erable to dispose of submarines in the ocean, then the 
possible continuance of a ban against such disposal could 
restrict the options available with no technical basis 
for such restriction. Sea disposal of low-level radio- 
active material is clearly permissible under international 
law. The London Ocean Dumping Convention of 1972, to which 
the United States is a signatory, allows disposal of low- 
level radioactive material in the ocean. Other foreign 
nations are currently disposing of low-level radioactive 
material in the North Atlantic under the provisions of the 
London Convention. 
