601 



As examples of outstanding issues which should be dealt with in 

 the context of the moratorium, our comments addressed such con- 

 cerns as: Difficulties in monitoring deep sea ecosystems; potential 

 food chain pathways, which relates to the question that Delegate 

 Sunia raised about the incremental effects of dumping; and indi- 

 rect effects. These same concerns and others were addressed by 

 EPA in an analysis that we viewed as a very thoughtful and con- 

 structive critique of the Navy's draft EIS. 



As a result of these and other concerns, we recommended that 

 the Navy delay the issuance of a Final EIS. Instead, they should 

 direct their attention to answering outstanding scientific questions, 

 and issue a supplemental draft EIS after the expiration of the mor- 

 atorium. I note that it was encouraging to see that 53 members of 

 the House of Representatives expressed similar views in a recent 

 letter to Navy Secretary John Lehman. 



Third, it is our view that further legislative action is needed in 

 the context of the Ocean Dumping Act. To date, there is not 

 enough adequate evidence of good-faith compliance by Federal 

 agencies with the moratorium's intended purpose. 



For this reason, we believe that the moratorium should be ex- 

 tended, that guidance should be given as to what is expected from 

 Federal agencies during the moratorium in terms of a comprehen- 

 sive research and monitoring program, and that a report on the 

 implementation of that program be submitted to Congress at some 

 appropriate future date. 



It is encouraging to hear from Mr. Sjoblom, and to read in Dr. 

 Byrne's written submission, that such a program is being devel- 

 oped, and that it is expected to be completed in 1984. Having par- 

 ticipated as a witness in your subcommittee's November 1980 over- 

 sight hearing on this same issue, however, there is a distinct deja 

 vu element to the representations being made today by EPA and 

 NOAA. 



Fourth, in relation to our recommendation that the moratorium 

 be extended, we also believe that regulatory revisions relating to 

 ocean disposal to radioactive wastes should be postponed until after 

 the research and monitoring program has been implemented. 



Fifth, Mr. Lawrence, of DOE, has described that Department's 

 seabed disposal program for high-level radioactive wastes. With re- 

 spect to those ongoing activities, our prepared testimony describes 

 some instances where there should be greater opportunity for 

 public participation. Program accountability also would be well 

 served by making special efforts not to overlap environmental and 

 technical feasibility work with later engineering feasibility work. 

 Significant overlap blurs the program's breakpoint review opportu- 

 nities. An example cited in my testimony, is the upcoming ISHTE 

 study, the Institute heat transfer experiment. That study will pro- 

 vide important information that will be useful in determining 

 whether to go forward with substantial engineering work. 



Turning to the international front, as a first area of concern, ref- 

 erence has been made to the London Dumping Convention's mora- 

 torium and scientific review that is under way. As you know, I was 

 a participant in the convention's seventh consultative meeting, rep- 

 resenting Greenpeace International, which actively supported the 

 adoption of the moratorium. The environmental coalition on whose 



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