268 



saw approximately 200, and examined the sediment around even 

 fewer. There is no way you can tell from the outside of a 55-gallon 

 drum its internal configuration and whether it has a lead shielded 

 canister of high level waste on the outside. And, as I said before, 

 EPA has not looked at the concrete forms, some of which had 

 recorded external emissions of 1,000 millirems per hour or con- 

 tained 1,000 curies of radioactive material, or the high level waste 

 containers. 



One reason their samples may not be representative is the EPA 

 expeditions never look in the right place. Chart 18645 is an oceano- 

 graphic map of the Farallon Island region. And point C is the 

 location where EPA has done their research for the 6,000 foot 

 dumpsite, and where they maintain that over 44,000 containers 

 were disposed. 



Then we must look at the areas where the three AEC licensees 

 were allowed to dump their nuclear waste material. The square 

 area illustrated by dashes is the dumpsite in which the Nuclear 

 Engineering Co. was allowed to dispose of their waste under their 

 license issued October 22, 1958. Note that the EPA site is not 

 located inside this licensed area, and SVa miles from the center of 

 the dumpsite, point D is the disposal site in which the U.S. Naval 

 Radiological Defense Laboratory, the Ocean Transport Co., and 

 later the Nuclear Engineering Co. used as center for their dumping 

 operations in 1950 and 1960. They were required to unload the 

 nuclear waste material within 5 miles of this point, which is the 78 

 square mile circle drawn on the map. As you can see, the area 

 which EPA examined is not in the dump zone, and is 7 miles from 

 the central dump coordinate. 



The Nuclear Engineering Co.'s license was later amended to 

 require them to dump in the trapezoidal area marked on the map 

 as a "Chemical Munitions Dumping Area." On April 8, 1962, at the 

 request of the State of California, the AEC changed the Naval 

 Radiological Defense Laboratory dumpsite to this same trapezoidal 

 area. Again, we can see that the area in which EPA explored is not 

 in the dumpsite, and is over 6 miles from the center of the dump- 

 site. So the question remains, do the few drums EPA examined 

 truly represent all the drums since their tests were conducted 

 outside these licensed dumpsites, and failed to include the high 

 level waste concrete blocks and drums. 



Which brings us to the military, probably the single largest 

 nuclear waste dumper in the country. 



Only a portion of the military's disposal operations even came 

 under the purview of the AEC. Any wastes generated from oper- 

 ations which are exempt from the Commission's regulatory author- 

 ity under section 91(b) of the Atomic Energy Act, are also exempt 

 from the Commission's safeguards provided that the waste remains 

 in the possession of the military until the ultimate disposal. 



The Army shipped all of its waste material originating west of 

 the Mississippi River to the Dugway Proving Ground in Utah. 

 According to their standard operating procedures manual, the ma- 

 terial was then shipped to the U.S. Naval Radiological Defense 

 Laboratory, in San Francisco, which performs their ultimate dis- 

 posal. The wastes were much more hazardous than we have been 



