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are crushed — and photographs taken by EPA show a significant number have been, 

 presumably due to defective packaging — by the over 3,000 pounds per square inch of 

 water pressure at the disposal site, or the deterioration resulting from a combina- 

 tion of sea water, pressure, and the passage of years. According to the Congressional 

 Research Service 6 to 8 inches of concrete can decrease the radiation emissions by a 

 factor of ten, and the lead insulation may also reduce the internal radiation emis- 

 sions by a factor of ten. So the internal radiation levels may be much higher than 

 the 200 millirem external radiation. Possibly between 2 and 20 rems per hour. As a 

 comparison the NRC only allows workers in an Atomic Energy Plant to be exposed 

 to 5 rems per year. This is material which meets the AEC definition of "high level" 

 materials. One can only speculate about the danger posed by the drums which an 

 AEC inspector found on a ship which measured over 1500 millirems on the outside 

 of the drum. These high level drums originated at Livermore Laboratories. 



This brings us to the mysterious concrete forms which were used to dispose of 

 large radioactive materials. Other than referring to "experimental matrices" in 

 their report to this Subcommittee in 1978, EPA has never given us any information 

 about their content or potential danger to the marine environment. I have here 

 drawings which I understand were made by Livermore Laboratories for the compa- 

 nies who disposed of their waste material. Diagram D-0048 illustrates one such 

 concrete structure. Inside lies a beryllium nuclear warhead, for which the disposal 

 company said "Considerable risk would be involved in cutting the cone to fit regular 

 barrels." 



Drawing D-0045 shows us the "High Level Configuration of a Solidified Liquid 

 Drum Block." As you can see from this illustration the "High Level" drum is 

 located closer to the center of the block to provide additional concrete insulation. 

 Again, concrete insulation can decrease the radiation emissions over from over two 

 rems internally, to under 200 millirems externally. And finally in Drawings D-0049 

 and D-0042 we have two more specially designed "High Level" waste containers, 

 with between 10 and 8 inches of steel and concrete insulation to reduce the high 

 internal radiation levels. To my knowledge the EPA has never seen, let alone 

 examined one of these structures which weigh at least 10 tons each. 



EPA may say if "high level" drums were present it would have been noticed in 

 their samples. Which leads us to the crux of the whole issue — ^just how representa- 

 tive of all the wastes dropped were the few drums which EPA examined. There 

 were over 48,000 radioactive waste containers dumped in the Pacific Ocean, EPA 

 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 1500 millirems per hour or contained 1,000 curies of radioac- 

 tive 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 Oceanographic map of the Farallon Island 

 region. Location A on the map is the approximate location of the 150 drums of 

 radioactive material which were dumped in three barge trips. Location B is the 

 3,000 foot dumpsite where EPA has done exploratory work. According to EPA there 

 are 3600 drums at this site. 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 which the AEC licensees were allowed to dump 

 their nuclear waste material. The square area illustrated by dashes is the dumpsite 

 in which the Nuclear Engineering Company 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 5y2 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 Company, and later the Nuclear Engineering Company used as 

 center for their dumping operations in 1959 and 1960. They were required to unload 

 the nuclear waste material within five 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 seven miles from the central dump coordinate. 



The Nuclear Engineering Company'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 9, 1962, at the request of the State of California, the AEC 

 changed the Naval Radiological Defense Laboratory dumpsite to this same trapezoi- 

 dal 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 dumpsite. So the question 

 remains, do the few drums EPA examined truly represent all the drums since their 



