350 
up by pretreatment, they can and it works. There are examples of 
it across the country. 
Regarding dredge spoil disposal, we support the provisions of the 
current law requiring analysis of the dredge material before dump- 
ing and that prohibit dumping unless it is shown through bioassay 
and bioaccumulation testing that the spoils are safe for ocean dis- 
posal. Substances that do not pass the tests should not be dumped 
into the ocean. 
The Sierra Club will be submitting for the record a list of the 
uses (see letter on p. 351) to which we believe a dumping fee should 
be put. As I read the draft bill, it suggests a dumping fee that 
would be oriented mainly toward paying the cost of the specific 
dumping operation. 
The suggestions we will submit have to do with expanding the 
purposes beyond the particular dumping operation to include such 
things as EPA research into new processes for reducing toxic con- 
tamination, including the development of new less polluting proc- 
esses; research into methods of municipal pretreatment and terti- 
ary treatment; cleanup projects such as PCB dredging; assistance 
to industry for pretreatment and source reduction; planning funds 
for establishing land application programs; and land application 
sitings, including money for land through purchase or condemna- 
tion; and packages of mitigation measures. 
Regarding radioactive wastes, those dumpsites already located 
must be carefully evaluated before any further dumping is allowed. 
We support the moratorium, though it should be total and indefi- 
nite, excepting only dumping of wastes for limited research pur- 
poses that are determined to be safe and proper by an independent 
group, such as the National Academy of Sciences. The moratorium 
should only be lifted when conditions specified by Congress are 
met. 
For instance, it is clear that we have no practical basis of knowl- 
edge to conclude that radioactive waste dumping is safe. Careful 
scientific studies at the Atlantic disposal site and past U.S. dump- 
ing sites might possibly yield criteria on which dumping could be 
based and specified by Congress. Of course, the reductions in 
NOAA’s budget are particularly inappropriate at this time, both 
regarding radioactive waste and any other kind of dumping. In 
short, we feel that nothing short of a clear congressional statement 
will stop this dumping. 
Thank you, Mr. Chairman. 
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