641 



The Honorable Norman D'Amours 



December 5, 1983 



Page 2 



My written testimony and overview response to your question 

 also referenced the environmental organizations' comments that 

 were submitted to the Navy on June 30, 1983 in response to its 

 Draft EIS on the disposal of obsolete nuclear submarines. Those 

 comments addressed technical, legal and policy considerations, 

 including eleven scientific concerns that were not adequately 

 addressed in the Draft EIS. A few of those eleven concerns are 

 submarine disposal-specific, in focus, but all of them represent 

 issues which should be addressed in the context of a broader 

 research and monitoring program. Those eleven issues include: 

 difficulties in monitoring deepsea ecosystems; potential pathways 

 for transport of radioactivity towards humans; site-specific 

 questions; potential availability of radioactivity in the deep 

 ocean environment; cumulative impacts; indirect effects; faulty 

 cost estimates; irretr ievability ; inadequate consideration of 

 other alternatives; potential for accidents; and other data 

 deficiencies. Several of these concerns, among others, were 

 similarly presented to the Navy last June by the EPA in its 

 comments on the Draft EIS. 



The concerns addressed in the Center's August 1982 critique, 

 the environmental organizations' comments on the Navy's Draft EIS 

 on scientific considerations, the EPA's comments as well as other 

 comments on that Draft EIS, the various studies and reports cited 

 by EPA in its written testimony at the November 2nd hearing, the 

 Department of Energy's marine-related work on risks associated 

 with sea-bed disposal of high-level radioactive wastes, and other 

 information and concerns which have been pulled together for 

 purposes of the international scientific review of low-level 

 radioactive waste dumping and the Nuclear Energy Agency's Seabed 

 Working Group (SWG) work on high-level sea-bed disposal, all 

 represent examples of information which should be used as points 

 of departure for purposes of developing and implementing a 

 targeted research and monitoring program. 



As discussed in my testimony at the hearing, the 

 environmental organizations believe that the Congress should 

 adopt an amendment to the Ocean Dumping Act which directs EPA and 

 other federal agencies to develop and implement a comprehensive 

 research and monitoring program and to submit a report on the 

 results of that program within an appropriate timeframe. We also 

 recommended that the current moratorium be extended to allow 

 adequate time for that work to be done. 



At the hearing the EPA witness indicated that both EPA and 

 NOAA are currently developing a comprehensive research and 

 monitoring program in relation to radioactive waste disposal in 

 the oceans. NOAA's written submission advised that a working 

 group has been established under Public Law 95-273 to "develop a 

 coordinated national plan for research and monitoring to evaluate 



