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MONITORING OF U.S. DUMPSITES 



As you are aware, there has been recent controversy about the need for additional 

 monitoring to assure public safety from exposure to radiation from the abandoned 

 waste dumpsites. 



Last month (October, 1980) we had the opportunity to appear before a subcommit- 

 tee of the Committee on Government Operations to talk specifically about the 

 Farallon Islands and public health. Three issues arose in those hearings, as follows: 



(1) The problem of obtaining and assessing the records of past disposal operations; 



(2) The public health impact, if any, indicated by EPA surveys; and (3) The need for 

 future monitoring of existing dumpsites. 



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 environmental 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 desireable from a scientific and a public health point of view. 



In view of your subcommittee's previous interest in the monitoring 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 "market 

 place" monitoring. It is designed to address the public concern about the possibility 

 of elevated radiation in food. It consists of periodic radioactivity measurements of 

 fish and other sea food bought and eaten by the general public in areas near man- 

 made 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 material 

 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, radioactivity 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 "base- 

 line" monitoring. Baseline monitoring is particularly important to provide informa- 

 tion about the normal or ambient concentrations of marine radioactivity against 

 which to measure the impact of any future radioactive waste dumping. It is also 

 important because it provides fundamental data about the marine food chain. A 

 fourth type of monitoring in "compliance" monitoring. This is primarily a regula- 

 tory activity performed after dumping has occurred to verify that regulatory re- 

 quirements have been met. 



It is my view that market place, dumpsite, and baseline monitoring should all be 

 done. I am not optimistic that we at EPA can undertake monitoring to assure public 

 safety while still maintaining progress on the development of regulations to control 

 any future disposal of low-level radioactive waste. 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. 



During the past month, discussions about future monitoring and monitoring strat- 

 egies have intensified. Both NOAA and EPA are committed to developing a moni- 

 toring strategy, and high priority is being given to the development of a concise, 

 mutually-agreeable, statement of purposes and costs for the ocean monitoring of 

 radioactive materials. The legislative basis for these efforts is the Ocean Dumping 

 Act where the responsibilities of EPA and NOAA are described in Title I and Title 

 II, respectively. In areas where we don't have resources, we will seek more through 

 our normal budgetary process. 



An effort of this magnitude will require the assistance of other agencies as well. 

 Federal agencies, such as the Food and Drug Administration, the Department of 

 Energy (DOE), and the Nuclear Regulatory Commission (NRC), and States, such as 

 California and perhaps Massachusetts, Maryland and Delaware, would likely have 

 an interest. At this time the NRC and DOE are providing us with their records on 

 past dumping operations and locations to assess whether other sites, in addition to 

 the sites we have already surveyed, may have substantial quantities of radioactive 

 waste. We have also asked the Department of Defense to determine whether it has 

 additional information. 



