351 



On the public health question, our position has been clear for 

 some time. That is, although EPA does not recommend the past 

 dumping practices and would not permit those activities to be done 

 the same way today, our preliminary evaluation of their environ- 

 mental consequences indicates no harm to man or the marine 

 environment. It should be clearly recognized, however, that the 

 information we have collected is not encyclopedic. It does represent 

 a pioneering first step in developing general monitoring programs 

 for both abandoned and active dumpsites, but more information is 

 desirable from a scientific and a public health point of view. 



In the view of your subcommittee's previous interest in the moni- 

 toring of low-level radioactive waste dumpsites, I would like to 

 provide you with some ideas that have evolved since the hearings 

 in California. 



A first point on which we are making progress is understanding 

 the various kinds of monitoring that may need to be performed. We 

 see three, and eventually four, basic kinds of monitoring that need 

 to be considered. The first I shall call marketplace monitoring. It is 

 designed to address the public concern about the possibility of 

 elevated radiation in food. It consists of periodic radioactivity meas- 

 urements of fish and other seafood bought and eaten by the gener- 

 al public in areas near manmade sources of radiation. This assures 

 that there are no significant quantities of radioactivity reaching 

 man. 



The second type of monitoring I will call dumpsite monitoring. In 

 this type of monitoring, samples of water, bottom sediment, edible 

 marine organisms, and other biological species are collected to 

 examine the distribution of radioactivity in marine species in and 

 near a dumpsite. Such monitoring indicates how the waste materi- 

 al might be transported physically and biologically from the site 

 and potentially to man. A third type of monitoring deals with the 

 general distribution of radioactivity in the oceans; that is, radioac- 

 tivity from natural sources, fallout from nuclear weapons testing, 

 and radioactivity from other activities of man. This monitoring we 

 could call general marine environmental assessment monitoring, or 

 simply baseline monitoring. Baseline monitoring is particularly im- 

 portant to provide information about the normal or ambient con- 

 centrations of marine radioactivity against which to measure the 

 impact of any future radioactive waste dumping. It is also impor- 

 tant because it provides fundamental data about the marine food 

 chain. A fourth type of monitoring is compliance monitoring. This 

 is primarily a regulatory activity performed after dumping has 

 occurred to verify that regulatory requirements have been met. 



It is my view that marketplace, dumpsite, and baseline monitor- 

 ing should all be done. I am not optimistic that we at EPA can 

 undertake monitoring to assure public safety while still maintain- 

 ing progress on the development of regulations to control any 

 future disposal of low-level radioactive waste. 



The latter area, of course, being the concentration of our activi- 

 ties in the past. 



If progress is to be made on both of these fronts, it probably will 

 require a strong cooperative interagency program that pools the 

 capabilities and expertise of the cognizant Federal agencies. 



