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tistics, bioeffects, geology, radiochemistry, radiation dosimetry, cor- 

 rosion, economics, and other matters. 



These experts came from within the EPA, the National Laborato- 

 ries that are doing various studies for us, or were hired from out- 

 side these already existing avenues to provide additional expertise. 



EPA gave this environmental statement a careful review, be- 

 cause it represents the first serious consideration of ocean disposal 

 of radioactive materials that has been submitted to EPA since we 

 were given responsibility under the act in 1972. EPA initially sub- 

 mitted extensive comments to the Navy Department on June 29 

 and additional comments on July 29. 



The amendments to the Marine Protection and Sanctuaries Act, 

 as contained in the amendment to the Highway Improvement Act, 

 were similar to language proposed earlier in House Rule 6113. The 

 agency's views on this bill were provided in earlier testimony last 

 year. We understand from the Congressional Record that these 

 amendments — and you reiterated that, Mr. Chairman, this morn- 

 ing — were passed to allow additional information to be gathered 

 from research such as I have been describing, and allow this to be 

 done in a calm way. 



While EPA is continuing studies and has added some new re- 

 search to establish an improve scientific understanding, the net 

 effect of the amendments may be actually to discourage research 

 that would be beneficial to answering the difficult questions re- 

 garding potential fate and the impact of radioactive materials in 

 the ocean. 



A potential permit applicant has to evaluate whether the effort 

 required to meet requirements is worth the cost in view the likeli- 

 hood of Congress taking an action within 90 days. The whole effort 

 could be nullified at considerable loss to the applicant and EPA by 

 Congress simply not taking an action in the time required. If ocean 

 disposal cannot be considered a reasonable alternative for practical 

 purposes, then only land disposal options will be considered. Since 

 we in EPA have also to be concerned with environmental protec- 

 tion of our land, and our food resources, we favor an approach to 

 waste management that allows consideration of all reasonable dis- 

 posal options consistent with our international obligations and a 

 careful evaluation of the environmental effects of those options. 



Such a waste management approach would allow waste disposal 

 decisions that optimize protection for all parts of the environment. 



I might add, the Environmental Protection Agency is currently 

 involved in development of standards for the land disposal of both 

 low level and high level radioactive wastes, so we are very much 

 involved with all phases of this work. 



Turning to the international effort, EPA has taken the initiative 

 to periodically convene an interagency group of experts on policy 

 level people to consider what we might do to develop our positions 

 for future LDC meetings. One of the areas has been organized in a 

 radiation work group. This group has met several times to consider 

 the actions the United States should take. We developed in re- 

 sponse to the Secretariat a list of documents and submitted them 

 to the IMO and to the International Atomic Energy Agency. We in- 

 tended to be involved fully in the international scientific review 

 over the next 2 years. 



