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The Honorable Norman D' Amours 



December 19, 1983 



Page 2 



relation to its Draft EIS on obsolete nuclear submarine disposal, 

 a copy of which has been provided to the Subcommittee, we 

 recommended several specific monitoring strategies, including 

 pathway/food chain effects studies (at pp. 16-32) that would 

 provide useful documentation. Reliable risk assessment models 

 also would contribute valuable information. "Proving" that 

 dumping of low-level radioactive wastes is "safe" involves 

 judgment calls. It is impossible, given the extremely long half- 

 lives of some radioisotopes, to ever prove absolute safety, but' 

 much more needs to be done through marine scientific research and 

 monitoring to ensure that such practices are safe, in a relative 

 sense. The important point behind such a revised burden of proof 

 is that the proponents of such dumping would have an affirmative 

 duty to present authoritative evidence which shows that radwaste 

 dumping is safe. To date the environmental organizations do not 

 believe that enough attention and resources have been devoted to 

 that effort by the proponents of such practices. 



Question #2: In your opinion, has the development of the United 

 States domestic policy and program implementation on ocean 

 dumping of radioactive waste been open to public participation? 

 If not, could you please discuss where public participation has 

 been restricted or denied? 



a. You mentioned that the DOE research conducted by 

 the Sandia Laboratories on subseabed disposal of 

 hi-gh-level radioactive waste, while adequate, could 

 be improved by broadening the opportunity for 

 public participation. Could you please elaborate 

 on what you would like to see involved in opening 

 this process to public participation? 



b. Has the development of U.S. policy on international 

 radioactive waste disposal been an open process 

 and, if not, please elaborate on the areas of 

 possible improvement? ' 



Answer: In my opinion, the development of United States' 

 domestic policy and program implementation on ocean dumping of 

 radioactive wastes has not been open to public participation. 

 The EPA/DOS-sponsored Ocean Dumping (advisory) Committee provides 

 limited opportunities for the public to participate in the 

 development of U.S. policies in relation to the London Dumping 

 Convention, but there should be a similar mechanism (much 

 improved) that would enable persons and organizations outside the 

 government to participate systematically in domestic policy and 

 program implementation. There have not been adequate 

 opportunities to participate in the development of the EPA/NOAA 

 comprehensive research and monitoring program that is now 

 apparently under development again after a two-year hiatus. No 



