654 
The Department of the Ariny, on behalf of the Depart-— 
ment of Defense, also opposes section 3(4) of the bill 
which singles out low-level radioactive waste for uniaque 
and highly restrictive treatment. Specifically, the bill 
arbitrarily establishes a two-year moratorium on diswvosal 
of low-level radioactive waste in the ocean. The Depart- 
ment cf the Army is concerned that the two year morato- 
rium on duriding of low-level radioactive waste in section 
3(4) woulda prohibit or interfere with the dumping of 
dredged material wnich may be contaminated by incidental 
Guantities 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 froin the Committee Revcort of the Committee on 
tierchant liarine 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 
Jost dtl g 
Also, the proposed moratorium may ultimately inter- 
fere with the vlans of the Devartment of the Navy to 
Gisvose of defueled, decommissioned nuclear submarines. 
Fithough tne specific provision in H.R. 6113 would have 
no invaediate 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 environnientally acceptable and pref- 
erable to disvose of submarines in the ocean, then the 
~wossible continuance of a ban against such disnosal 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 
lav. Tne 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. 
