600 



Working with and through the Center for Law and Social Policy, 

 this environmental coalition has directed special attention to issues 

 surrounding ocean diposal of radioactive wastes. 



Radioactive materials are among the most dangerous pollutants 

 for the marine environment. Much still needs to be learned about 

 the risks associated with their disposal in the ocean. 



Pending the results of further research and monitoring, neither 

 the U.S. Government or other governments should permit our 

 oceans to be used as a disposal medium for such wastes. 



In my prepared testimony, Mr. Chairman, I address several do- 

 mestic and international activities. The concerns and recommenda- 

 tions which we have presented deal with programmatic, legal and 

 policy initiatives that are either ongoing or proposed. I would like 

 to highlight those concerns. 



On the domestic front, the earlier testimony and colloquy ad- 

 dressed several matters which we believe merit further attention. 



First, reference has been made to the recent amendments to the 

 Ocean Dumping Act. We believe that those amendments make 

 beneficial changes to the law. 



We support the adoption of the moratorium; the inclusion of the 

 radioactive materials disposal impact assessment requirements; 

 and the requirement that Congress give its approval to any pre- 

 liminary permit approval by EPA. 



The adoption of the moratorium reflects the view that a more de- 

 liberate pace is needed for consideration of the ocean option. It pro- 

 vides time for the completion of more detailed research and moni- 

 toring of the risks and uncertainties that exist. 



As you indicated in your opening statement, the moratorium was 

 premised on the fact that reliable information on past dumping 

 was, and in our view, remains either inadequate or lacking. 



Unfortunately, Federal officials appear to view the moratorium 

 principally as a time for inaction on the research front. Mr. Sjob- 

 lom's earlier testimony, and Dr. Byrne's written submission on 

 behalf of NOAA, which I took a brief look at earlier this morning, 

 indicate that numerous studies have been completed or are on- 

 going. The information from those studies should be very helpful. 



Very few of those studies, though, including the Massachusetts 

 Bay field survey done in 1981-1982, appear to focus on risk assess- 

 ment in relation to past U.S. dumpsites and potential future dump- 

 sites. 



They fail to address from a survey perspective the questions 

 about deep sea ecosystems and food chain pathways from the site 

 of radioactive waste through the marine environment, and ulti- 

 mately, the potential hazard to human health. 



While all of the studies mentioned in the EPA and NOAA testi- 

 mony should assist those agencies and others in assessing the risks 

 of radioactive waste disposal, a more accurate assessment of the 

 hazards of past dumping still is needed, and past dumpsite and 

 "test" site monitoring still is needed to provide data and a sound 

 predictive capability and validation system. 



Second, these concerns and others were presented in comments 

 submitted by the environmental coalition to the Department of 

 Navy in response to its draft EIS on the disposal of obsolete nucle- 

 ar submarines. 



