642 



The Honorable Norman D'Amours 



December 5, 1983 



Page 3 



the marine option for disposal of low-level radioactive wastes, 

 and to facilitate implementation of this plan by the appropriate 

 agencies." It was encouraging to hear that such a plan is in 

 process. As noted in my testimony, however, similar efforts were 

 initiated in 1980-81 following a hearing before your Subcommittee 

 on November 20, 1980. A revised draft of that plan was completed 

 by the fall of 1981, but it was never finalized. 



My written testimony listed the five objectives, or 

 purposes, that were contained in the 1981 revised draft plan. 

 With the exception of the fifth objective, the first four could 

 be used as part of an amendment to the Act that would describe 

 the contents of a required research and monitoring program. 

 Consistent with the concerns expressed in our August 1982 

 critique and the June 1983 comments on the Navy's Draft EIS, 

 however, the fifth objective, i.e., "to test our present belief 

 that previous ocean dumping of radioactive wastes is not a threat 

 to health or to the marine environment," should be revised. 

 Instead of referencing any present beliefs based on extremely 

 limited field data and preliminary assumptions, that objective 

 should seek "to assure the public that previous dumping of any 

 dumping of radioactive wastes is not a threat to human health or 

 the marine environment." 



Such legislative guidance in the Ocean Dumping Act along 

 with the other amendments that were recommended in my written 

 testimony, would assist both Congress and the federal government 

 in carrying out their respective responsibilities. It would 

 provide the Congress with a benchmark for assessing the adequacy 

 of any program that is developed. With respect to the federal 

 agencies, it would clarify any uncertainties that might remain as 

 to the purpose of the moratorium, and it would provide program 

 end-points that could be cited for purposes of securing the 

 necessary budget resources. 



In this response I have suggested some of the scientific 

 concerns that need to be addressed in a comprehensive research 

 and monitoring program, as well as language that could be used to 

 provide statutory guidance in the development and implementation 

 of such a plan. In preparing this letter I discussed these and 

 other related issues with representatives of several of the 

 environmental organizations on whose behalf my testimony was 

 submitted. In talks with the Oceanic Society's President, 

 Christopher Roosevelt, we discussed a mutual desire to develop a 

 much more detailed set of research and monitoring strategies 

 which would be prepared through a focused workshop-type review of 

 the various sources of information cited earlier, among other 

 data and analyses. While neither the Center for Law and Social 

 Policy nor the Oceanic Society presently have the resources to 

 undertake such an effort, we intend to pursue that idea. 



