you are doing a service to the residents of this area, as well as the country generally by providing a forum where we can explain and clarify just what the situation is, and have others express their views on it as well.

The opportunity that we have today is to testify on EPA's assessment of the environmental consequences of the U.S. ocean disposal of radioactive waste which occurred between 1946 and 1970.

Low-level radioactive wastes are routinely generated by a wide range of military and nonmilitary operations, including nuclear powerplants, commercial manufacturing processes, and research and medical activities.

The bulk of these wastes are materials such as equipment, tools and lab clothes that have become contaminated by exposure to atomic radiation or by contact with radioactive materials.

Much of these wastes contain isotopes such as cobalt 60, strontium 90, iron 55, tritium, and cesium 137, and, at times, they may include small quantities of "source materials" such as uranium and thorium, or traces of special nuclear materials such as plutonium. Although they are called low level, these wastes are not harmless and care must be exercised in their handling and disposal. From 1946 through 1970 it was the practice of the U.S. Atomic Energy Commission to permit disposal of low-level radioactive waste materials either by shallow land burial at Governmentowned or licensed sites, or by ocean dumping at AEC-approved sites.

Because the materials were potentially hazardous, they were given special attention in transport and disposal. But because they were regarded primarily as garbage, unfortunately precise records were not kept of the specific contents.

Today, the records of the ocean dumping activities consist primarily of documentation drawn from AEC licenses and from logs indicating the general nature and quantities of the materials, the estimated radioactivity, and the coordinates of the dumping locations.

Unfortunately, these records do not indicate the specific isotopic contents of the waste materials. Records of military operations and government contractors, such as national laboratories, also may exist, but have not yet been located.

In practice, the materials generally were packaged primarily for the requirements of handling and transport. They were placed first in a variety of containers and then encased in 55-gallon steel drums filled with concrete. In the case of sludges and liquids, the wastes may have been mixed in directly with the concrete. The drums were then capped with concrete.

I would like to emphasize that these procedures, and at least some of the dump sites, would be considered seriously substandard today. EPA does not condone these past practices and would not license such activities today.

But, it should be noted that our preliminary evaluation of the environmental consequences of these dumping activities indicates that there has been no environmental damage as a result of these dumping operations. In this sense, we have been fortunate.

I would like to clarify our mandate to write criteria for future dumping and our schedule. We have scheduled criteria for publica

tion by 1985. This does not imply that the Agency is in a role of promoting the resumption of dumping. Rather, it is going to be in a state of readiness. Should persons apply for permits, we will have identified minimum criteria, minimum conditions before we would even consider processing such an application.

We agree completely with the Congressman's viewpoint that such resumption should not occur, unless we have adequate information on baseline and other factors with which we can assure the safety and integrity of any such practices.

Pursuant to the mandate of the Ocean Dumping Act of 1972, EPA initiated a series of site surveys of the ocean nuclear waste dump sites to determine if there had been any environmental damage resulting from past dumping practices, and to provide a technical basis for the development of regulatory criteria.

We did an initial survey of the Farallon Islands site in 1974 and follow-up surveys in 1977.

In the Atlantic Ocean a similar series of investigations was undertaken at the 2,800 and 3,800 meter sites. A preliminary sampling team was sent out in May 1974. In 1975 three dives in a manned submersible vehicle were made to document the condition of drums and to take a variety of samples. In 1976 a waste drum was recovered for detailed laboratory analysis to assess the longterm integrity of the drums.

Even in such fundamental areas as the determination of background levels of radionuclides, it is difficult to characterize the ocean environments. There are deficiencies in the data and there is no universally accepted method of data interpretation.

To determine background levels, it is necessary to review the existing literature for credible measurements or previous estimates of radionuclide levels in various locations, and to calculate, from the most closely related data, what the expected levels of background radiation should be at particular locations today.

In the case of biological samples this is especially difficult because the baseline data is so sketchy. There can be so much variation in the bioaccumulation of different radionuclides from species to species that extrapolation of the data is highly uncertain.

Mr. MOFFETT. Excuse me for a moment. There are some seats where the EPA was sitting, if some of you in the back would like to take them. If some of the younger people would like to sit on the floor up here, that is about the best we can do. You are welcome to do that, along the front of this bench.

OK; sorry to interrupt. Please proceed.

Mr. HAWKINS. Well, given the uncertainties that I have just mentioned and the lack of adequate base-line information in many respects, you can appreciate that EPA work in this area comprises an initial survey of the major U.S. ocean dumping sites for nuclear waste which is neither comprehensive nor complete.

It is pioneering work, and the data we have collected includes sediment and water samples; surveys of infaunal biota, benthic organisms, and midwater species; investigations of physical, chemical, and biological mechanisms affecting radionuclide transport and behavior; and detailed corrosion analysis of the waste containers. Here are some of the things we have learned:

First, although approximately 75 percent of the canisters appeared to be intact, a significant number have ruptured or deteriorated.

Second, we have found evidence of radioactivity in fish specimens, and the concentrations of radionuclides in the fish we have collected compare to the range of concentrations found in similar species taken from other areas where no dumping has occurred. For example, market basket samples from elsewhere in the country indicate approximately the same levels of radionuclides in fish as the levels found in specimens taken near the nuclear waste dump sites.

There is one caveat which I will mention in a moment concerning an americium measurement.

Third, radioactivity in this range has been associated with worldwide fallout which is a legacy of the atmospheric testing of nuclear weapons in the 1950's and 1960's.

Fourth, since we have little data from nondumpsite areas, we cannot say with certainty that the levels found at the ocean dump sites were caused either by fallout or by the ocean dumping.

For example, the levels are so low that the sources are indistinguishable. However, we can compare the levels of radionuclides found at the ocean dump sites with Federal guidelines for radiation exposure.

Fifth, and most importantly, our calculations of fish taken from the Farallon Islands indicate that human consumption of such fish would yield an annual estimated dose that is approximately 1,000 times lower than the dose from radionuclides occurring normally within the human body, based on an annual consumption of 45 pounds of fish per year.

If someone ate several times the U.S. national average, we are still dealing with a safety factor of several hundred, however. Sixth, the data suggest a coherent picture of radionuclide behavior which indicates that water soluble radionuclides are being dispersed and diluted to insignificant levels, while plutonium, which tends to behave as an insoluble particulate, settles rapidly to the ocean floor.

Once on the ocean floor, the plutonium appears to be entrapped by the sediments and rapidly mixed downward by the burrowing actions of polychaete worms.

In reviewing its data, EPA has focused on the findings regarding strontium, cesium and plutonium, and in this context I would like to review the nature of these findings for the committee.

One, strontium 90 was one of the radionuclides measured because of its known hazards and its relation to the foodchain, but no elevated levels were detected in any of the biological samples collected from dump sites.

Two, cesium 137 was detected in two specimens of ling cod by one researcher, and in pelagic fish and benthic organisms by another. The concentrations found in these biological samples have been compared to data for biological samples not associated with ocean dump sites, and found to be comparable. The ranges are also consistent with what would be expected as a consequence of fallout from past atmospheric weapons testing.

Three, in the case of plutonium, elevated levels were detected in two individual specimens of Dover Sole. The plutonium appeared only in the gut of the fish, which is itself inedible, and suggests that it was being picked up along with sediments in the food, but not being digested and taken into the body of the fish.

Nonetheless, EPA calculated the dose which would be expected if such fish were eaten in their entirety on a regular basis.

Mr. PANETTA. Are you talking about specimens that were drawn from this area or nationwide?

Mr. HAWKINS. These are Farallon Island samples.

The resulting estimated annual human dose would be approximately 0.01 mrem/year compared with a naturally occurring annual dose of 60 mrem/year to bone surfaces, and 25 mrem/year to bone marrow, which occurs naturally as a result of radionuclides normally found in the human body.

It should also be noted, contrary to widely publicized reports, that our data showed no plutonium in the edible portion of any fish.

In the case of americium, which is a decay product of plutonium 241, one researcher reported very high levels in the edible muscle of one kind of fish-the rattail-taken in the vicinity of the Atlantic 3,800-meter site.

The rattail is a bottom feeder which is not fished commercially in this country and which, to the best of our knowledge, is not being fished at all in the area of the dumpsite, but which is apparently harvested commercially in other parts of the world. The data in this case is complicated by several technical factors: One, the researcher who discovered the high levels of americium in bottom fish samples was not testing specifically for americium at the time of his work and was, therefore, not using state of the art techniques for this radionuclide;

Two, although high concentrations of americium were detected, no plutonium was found in the fish, despite the fact that americium is a decay product of plutonium;

Three, the levels reported were so high that they would be difficult to explain on the basis of fish feeding in the vicinity of a leaking waste canister;

Four, no elevated levels of americium had been found in the Farallon Island surveys.

Because none of the original laboratory samples were kept for subsequent analysis, it is impossible to retest those precise specimens now using state of the art techniques for americium detection, and it will now be necessary to collect additional samples for further analysis, and that is something that the Government intends to see gets done.

In light of the renewed interest in these past dumping practices, and as a consequence of a policy-level review of the site survey contract reports, the Office of Radiation Programs is currently revising its program schedule.

We are, as I mentioned, trying to determine the best way to review the americium matter and, at the same time, will be trying to complete our reviews of the outstanding contractor reports by early next year.

We have requested both NRC and DOE to undertake complete reviews of their records of AEC licenses and contracts, and expect that work to be completed early next year.

We have, incidentally, also reviewed the work and the allegations of Prof. Jackson Davis, but it is our view his statement appears to be based on errors in analysis. I will be glad to expand on that.

As you know, EPA's ocean research activities are circumscribed by law and the overall coordination of ocean research is governed by the National Oceanic and Atmospheric Administration.

We have spoken with NOAA several times in recent months about the necessity to expedite this research, and have talked with them within the past 2 weeks about the specific problems illustrated by our radioactive waste dumping review.

I think there is a general agreement that it is desirable to improve our baseline data as a priority among ocean research programs, and we will continue to work out the details with NOAA in coming weeks.

In response to the committee's earlier request, we have compiled a factsheet which provides a summary of currently available information from the historical record of dumping activities, a table of known dump sites, a list of the most relevant statutory authorities, and summaries of our contractor work at both the Atlantic and Pacific Ocean dump sites, and we have submitted this factsheet for the record.

I would like now to introduce Mr. Robert S. Dyer, senior staff oceanographer and the project manager of the ocean dump site surveys, to review the site surveys in more detail for the committee.

We can either take questions now or later.

Mr. MOFFETT. Without objection, Mr. Dyer has testimony which will be considered as part of the record. We would prefer that that be summarized in some fashion.

Don't you have a presentation as well?

Mr. DYER. Yes, Mr. Chairman.

I have a series of slides, if you would like to see them. Can we go right to the slides?

Mr. MOFFETT. The subcommittee will come to order, please.
Let's see if we have this.

Could we ask you to turn the lights back on.

Go back quickly to the maps at the beginning because they might have a little more meaning now. We will be able to see them better.

Mr. DYER. Is there a particular map you would like to see? Mr. MOFFETT. Start from the beginning and show us those first three or four with a quick comment.

Mr. DYER. This represents a report to us by a contractor who did an independent analysis on what historical records he could find about the Farallon Islands dump site usage.

The primary information here is from Arnold Joseph's report to the Atomic Energy Commission in 1957, and again the sites of interest are sites 1, 2, and 3. I believe, yes, it is rather hard to read, but the San Francisco Bay is on the right and we are looking at sites 2 and 3, roughly 40 to 50 miles offshore.