688 



GREENPEACE U.S.A. 



Washinpon. DC 20009 



6 December 1983 



The Honorable Norman E. D' Amours 

 Subcxannittee on Oceanography 

 2242 Raybum House Office Building 

 Washington D.C. 20515 



Dear Rep. D' Amours: 



RE: COMMENTS TO THE MERCHANT MARINE & FISHERIES COMMITTEE 



on the 

 OCEAN DUMPING OF RADIOACTIVE I'JASTE 



Thank you for allowing us to include these cctrtnents to the record of the 

 Canmittee's oversight hearing on radioactive waste ocean dumping. The 

 contents briefly elaborate on the issues of EPA' s scientific studies to 

 monitor and research the consequences of past radioactive waste ocean duitping 

 and the IAEA's "de minimus" standards for defining nuclear wastes to be 

 duirped at sea. These issues and others of concern to Greenpeace were 

 presented in the testimony for Clifton E. Curtis of the Center for Law and 

 Social Policy for the environmental coalition on 2 Novaiiber 1983 before the 

 subcaimitee . 



Greenpeace believes that the historic radioactive waste diitpsites ' 

 already provide the EI'A with anple opportunity to examine the consequences of 

 ocean dunping in the Atlantic and Pacific Ocean. A scientific review must 

 atteitpt to determine the effects and fates of radionuclides on benthic and 

 marine creatures. In particular, we would urge the EPA to investigate the 

 old radioactive waste dunpsites to determine and publish: 



- sublethal effects of radioactivity on benthic and other marine 



creatures; 



- an ecosystems analysis of radionuclide transport within the 



particular marine food-chain; 



- life-cycles of benthic and other deep-sea creatures and; 



- other needed relevant data as listed in the environitental testimony. 



Without this information, it is impossible for the EPA to understand the 

 environmental consequences of ocean disposal and to conduct the type of 

 balanced cross-media analysis that is required by the Ocean Dumping Act. 



The lack of adequate or conplete records kept on our past dumping 

 operations-^, combined with the evidence of high-level nuclear waste dunping 

 at sea before 1970^ only adds to the inperative of checking the risks 

 associated with ocean disposal by further first-hand looks at the old 



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