612 



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B. Navy Interest in Scuttling Obsolete Nuclear 

 Submarines 



These and numerous other technical, legal and policy con- 

 siderations were presented in comments submitted by the environ- 

 mental coalition to the Department of Navy on 30 June 1983 in 

 response to its Draft EIS on the Disposal of Decommissioned, 

 Defueled Naval Submarine Reactor Plants .*/ The Navy's interest 

 in ocean disposal of obsolete nuclear submarines is the most 

 advanced federal agency program that is contemplating a return to 

 the oceans for radioactive waste disposal. As examples of 

 outstanding issues which should be dealt with in the context of 

 the current moratorium, our comments to the Navy discussed eleven 

 scientific and technical considerations which were not addressed 

 adequately in the Draft EIS. Those issues include difficulties 

 in monitoring deepsea ecosystems; potential pathways for 

 transport of radioactivity toward humans; site-specific 

 questions; potential availability of radioactivity in the deep 

 ocean; cumulative impacts; indirect effects; irretrievability; 

 and alternatives not considered. The Navy's failure to have 

 answered those scientific and technical concerns in its Draft EIS 

 deprives government officials, members of Congress and citizens 

 of information which is essential to making informed decisions 

 among alternative disposal methods. The coalition's comments on 

 the Navy's Draft EIS also apply the legal requirements of the 

 National Environmental Policy Act and the related CEQ guidelines. 



jj[/ A copy of those comments have been previously provided to 

 staff members of this Subcommittee. 



