The Honorable Norman D' Amours 



December 19, 1983 



Page 3 



documents have been released in support of that evolving program 

 for public review and comment. The Navy's Draft EIS on the 

 disposal of obsolete nuclear submarines offered a significant 

 basis for reviewing their ocean disposal option, but several of 

 the environmental groups and my organization found it very 

 difficult to gain access in a timely manner to the back-up 

 studies that could have been made available far earlier than was 

 the case. Earlier and more complete access to backup technical 

 studies would have facilitated more informed public input and 

 comment. There were similar difficulties surrounding 

 environmental organizations' efforts to receive pertinent data on 

 the Department of Energy's examination of sea-disposal for FUSRAP 

 wastes. 



In response to Question #2(a), my written testimony 

 indicated that the Department of Energy's Sandia Laboratories R & 

 D program has involved the public through certain program review 

 opportunities. Those public participation opportunities have 

 been very useful. As stated in my testimony, though, the 

 program's annual meetings and U.S. involvement in the 

 international OECD/NEA Seabed Working Group should allow for 

 public participation. This past week, I discussed further our 

 concern regarding the annual meeting with Dr. Anderson, Director 

 of the Sandia Laboratories. He informed me that the structure 

 and format of future annual meetings is under revision. There 

 should be procedures to allow non-governmental, non-program 

 people to attend future annual meetings, including the technical 

 discussions. Based on Dr. Anderson's initial comments on their 

 planned changes, it appears that our concerns regarding 

 participation in the annual meetings can be addressed 

 adequately. With respect to the NEA's Seabed Working Group, we 

 believe that the United States should press for the adoption of 

 procedures that would enable non-governmental, non-program people 

 to attend the task group and annual meetings as observers. 



In response to Question #2(b), the development of U.S. 

 policy on international radioactive waste disposal issues has not 

 been an open process. U.S. positions are too often developed and 

 finalized without any real opportunities for public 

 participation. There has been too great a focus within the 

 government on excluding outside participation until after the 

 various government agency officials have agreed on a common 

 position. When evolving U.S. positions are discussed publicly, 

 they are generally discussed too late in the process to permit 

 effective and thoughtful review of other views. The principal 

 mechanism for improving this situation would be through better 

 use of the Ocean Dumping (advisory) Committee. Dr. Tudor Davies 

 of EPA currently chairs that committee. His leadership of the 

 Committee has improved substantially the openness of the 

 discussions from the way in which those meetings were convened 



