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need to substantiate hypothesized radioactivity release and transport events in the deep ocean by in situ studies is even more important as the use of this option by other nations continues to increase and U.S. sensitivity heightens.

My last slide, Slide 38, is a reminder that there are many uncontrollable factors in conducting deep-sea surveys. Foremost among them are weather and equipment malfunctions. Other unexpected events can and do occur. Here we see a large freighter that came very close to sinking our research vessel, the Pandora. Since these sites are in the major transit lanes into and out of San Francisco, we notified the harbormaster in advance of our intended survey activities in this area. As long as visibility was good, the ships kept clear of the area. But when the fog moved in, the ships moved in dangerously close. This ship was on "iron mike" and never responded to our radio warnings. Only at the last minute did it change course enough to clear our ship.

This concludes my prepared statement.

Mr. MOFFETT. At this time the Chair calls our next group of witnesses, Dr. Michael Herz, Dr. Jackson Davis, and Mr. Jerry Cohen.

Remain standing, please. It is the practice of the subcommittee to swear you in. Please raise your right hand.

[Witnesses Herz, Lowenstein, Davis, Cohen, and Smith were sworn.]

Mr. MOFFETT. Please be seated. First of all, for the record, please identify yourselves, starting from our left.

STATEMENT OF DR. MICHAEL HERZ, OCEANIC SOCIETY AND
CHAIRMAN OF THE AD HOC SCIENTIFIC COMMITTEE ON
OCEANIC DUMPING OF RADIOACTIVE WASTES; ACCOMPANIED
BY JEROLD M. LOWENSTEIN, M.D.

Dr. HERZ. My name is Michael Herz.
Dr. LOWENSTEIN. Jerold M. Lowenstein.
Dr. DAVIS. My name is Jackson Davis.
Mr. COHEN. Jerry Cohen.

Mr. SMITH. Craig Smith.

Mr. MOFFETT. We do have statements from some of you, and your statements will be considered part of the hearing record, and if you would like to summarize, or paraphrase those statements, I think that the subcommittee would appreciate that. If you feel you must read them, fine. If there is a way to summarize them, that would be helpful. The most productive exchange is in questioning. We will start with Dr. Herz, please.

[Dr. Herz' prepared statement follows:]

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EXECUTIVE OFFICES: Magee Avenue. Stamford. Ct. 06902 Tei (203) 327-9786

OCEANS Editorial Office / Expeditions Office Bldg 240, Fort Mason, Sah Francisco, Ca 94123. Tel (415) 441-1104
Mid-Atlantic Regional Office PO Box 13357, Philadelphia Pa 19101 Tel (215) WA 5-6544

Recently attention has been refocused on the disposal of radioactive waste at ocean dumpsites located off the east, Gulf and west coasts of the United States. Although such practices were thought to have been limited to a relatively small number of locations, research into government documents by private organizations has reidentified at least 50 dumpsites, most of which apparently received radioactive waste.

We have convened as an ad hoc committee of scientists knowledgable in the areas of radiation health, toxic wastes and oceanography to review the situation and to recommend appropriate future actions to the Environment, Energy and Natural Resources Subcommittee of the House Committee on Government Operations. The individuals on the committee are opposed to dumping radioactive wastes in the oceans and have vigorously opposed it in the past.

We have reviewed the studies available to us performed by the Environmental Protection Agency (including those released in September 1980), the Lawrence Livermore Laboratory, the University of Washington, the New York Marine Sciences Research Center, and other parties (see bibliography). We have not reviewed the studies of radiation levels in fish conducted at various times in the past twenty five years by the State Health Department and the FDA, or the study of marine disposal of solid wastes off the west coast performed by the HEW Bureau of Solid Waste Management in 1969.

Some of the reviewed studies indicate the presence of radioactivitiy above natural background and fallout; however, we conclude that these studies contain no convincing evidence of a serious present or future threat to aquatic or human health either at the Farallon Island or at the 2800-meter Atlantic sites where the largest proportion of the waste was dumped.

We find that many of the results reported in these papers can be explained by natural radioactive elements, such as radium and potassium-40 (half-life 1.3 billion years), or by fission, products resulting from fallout of nuclear weapons tests in the atmosphere.2

We do not know how much additional information is yet to be released. The 26 September 1980 issue of the professional journal Science3 indicates that the Navy scuttled the defueled reactor from the nuclear submarine Seawolf at the 2800-meter Atlantic site in 1959. The reactor on this vessel had 33,000 curies of radioactive material, or over half again as much as the approximately 60,000 curies known to have been dumped by the AEC at all ocean dumping sites. Although this material, largely cobalt-60 (half-life 5.3 years), has decayed down to about 2,000 curies by now, it is clear that the record of what has been dumped in the ocean is far from being complete enough to serve as the basis for present hazard conclusions.

4,

Evidence of collapse of AEC containers at the time of deposition and of extensive rusting of metal drums indicates to us that seawater is already in contact with the contents of substantially all of the containers. Material not already released would be subject to slow release as concrete disintegrated in the presence of seawater. It seems probable that the peak release of radioactive material has occurred in the past. Colombo et al. (1979) have

made a conservative estimate that it would take 104 years for the concrete to disintegrate, with decreasing release of radioactive materials with time.

The "corrosion-resistant" stainless steel reactor from the Seawolf will doubtless rust through in time if it has not done so already. Its present state is unknown as the Navy has not been able to locate the reactor.

Review of the reports reveals cases of radionuclide movement from barrels to sediment with radioactivity decreasing as distance from the drum increases. Unfortunately, sampling was not done systematically. In view of the present state of the containers, contamination of sediments near them is to be expected. The important question is how much of this material has moved into organisms, particularly those people eat.

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The report of Schell and Sugai is the only report which appears to find radiation levels in fish higher than those due to fallout and natural radiation. These values should be compared to values in fish of the same varieties and size caught in other locations, in order to determine whether these fish contain more radioactive materials than similar fish elsewhere.

Shellfish are filter feeders which concentrate pollutants more than bony fish do. In view of the fact that mussels from Southeast Farallon Island have not had increasing or consistently elevated radiation values, there is no basis for immediate public concern about ingesting high levels of radioactive material in food. We believe that present evidence indicates a relatively small potential increase in radiation exposure from eating fish at the highest level of radioactivity detected by Schell and Sugai (see Table 1 and Figure 1); however, because we also believe in minimizing all avoidable radiation exposure, we recommend further investigation, as described below.

In order to determine the significance of the Schell and Sugai results, we recommend that an expanded monitoring program be developed for bony fish, shellfish and other marine food items. In view of uncertainty over the location of dumping sites, we recommend that the monitoring program extend along the entire affected coasts and that competent advice be obtained for a statistically sound sampling program.

The Farallon site is the largest ocean dump in the US waters, in terms of dumped containers. The site is within ten miles of Southeast Farallon Island, which has had an active biological field station since 1970. A wide variety of organisms use the island or adjacent waters, making sampling of a spectrum of potentially affected species relatively easy, and we recommend that such monitoring be initiated.

The island has been sampled for levels of radioactivity and other toxic materials in mussels since 1976 as part of the International Mussel Watch Program. Feather samples from a variety of birds could be collected easily and analyzed for levels of radioactivity. A variety of marine mammals annually mate and give birth on the island, offering a possible source of data on mammalian birth defects and infant mortality.

In the past, little consideration appears to have been given to systematic monitoring of the affected environment after dumping; the handful of

studies which have been done in the nearly 25 years since ocean dumping began have not adequately assessed impacts. While the difficulties imposed by the remoteness and depth of the disposal sites explain some of the deficiencies, future work should be more carefully organized.

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In 1969, it was estimated by Gunnerson that one and a quarter million barrels of chemical wastes were disposed of in Pacific coastal waters in 1968 alone; over 8 million tons of solid waste were dumped in the ocean. More than 60 million gallons of waste a year were dumped into the Gulf of the Farallons. The Navy has disposed of munitions near the radwaste dumping site. It is not known how many persistent and/or bioaccumulating materials have been dumped. Philadelphia sewage sludge alone was responsible for deposition in the ocean of 12,000 pounds of cadmium and 500 pounds of mer12 cury a year. Although various federal and state laws have reduced ocean disposal of wastes, the mercury, cadmium and lead in the oceans neither biodegrades nor decays.

We recommend that any bony fish and shellfish monitoring program in addition to radiation also cover heavy metals, PCBs and other toxic materials. It would be unfortunate to miss a major chemical hazard while studying a minor radiation problem.

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