448 



Mr. Hughes. Now, if we were to work on the assumption that 

 canisters could not be constructed to contain low-level wastes, in 

 your judgment would that be, per se, a violation of this section of 

 the statute? 



Mr. Mattson. No; if we were to make that decision today, that it 

 was impossible to make a canister, independent of cost, to meet 

 that test, then we could say today what the requirements are for a 

 permit. There shall not be any permits is what we would say. 



Mr. Hughes. That's what I'm trying to find out. 



Mr. Mattson. That case is an alternative available to EPA. It 

 could very well be that by the time we get to 1985 and issue our 

 criteria that they are so prohibitive in terms of cost that ocean 

 disposal is not practical compared to land-based disposal. 



Mr. Hughes. Let me take you through the second stage. 



Obviously, in talking in terms of whether or not canisters can be 

 constructed to contain low-level radioactive waste, you have got to 

 talk in terms of the timeframe. 



Mr. Mattson. Yes, sir. 



Mr. Hughes. What, in your judgment, is the timeframe that 

 would be required to comply with the terms of the statute, because 

 obviously a canister can be constructed to contain low-level 

 wastes 



Mr. Mattson. We can make it independent. 



Mr. Hughes. Ten years? What timeframe are we talking about? 



Mr. Mattson. We can make it a variable timeframe, because of 

 the fact that radioactive materials have different half-lives; that is, 

 it takes different species different lengths of time to decay. That's 

 the reason that in the regulations that have been issued so far the 

 concept of innocuous levels was used. So something with an 8-day 

 half-life will decay to innocuous levels very rapidly. The canister 

 that you could put it in and put it in the ocean, for example, might 

 be much less complex than the canister you would want to put 

 plutonium in with a 24,000-year half-life. So it would vary. 



I think you can understand, at least theoretically, there are some 

 radionuclides or low-level wastes that could be put in the ocean in 

 canisters that you would reasonably expect to survive through 

 enough half-lifes to reach innocuous levels. Now, whether it's eco- 

 nomical to do that and to separate radionuclides that way and still 

 pursue the option, I don't know. Those details haven't been thought 

 out, and criteria haven't been developed. 



Mr. Hughes. How far along are you on that type of criteria? 



Mr. Mattson. Well, at this point we have spent 



Mr. Hughes. I don't know how anxious the Navy is to dump. 



Mr. Mattson. We have spent on the order of $1 million or so on 

 this kind of research. We have spent, in terms of staff years, 

 probably a half a dozen with EPA employees. We have surveyed 

 sites and gathered data on the point sources of elevated radioactiv- 

 ity in the marine environment for the first time — no one has ever 

 done that before. We have proven that there is a technology availa- 

 ble for learning more. We have contractors who are assembling the 

 kinds of considerations that ought to go into siting criteria, much 

 like the kind of work that the Atomic Energy Commission would 

 have done years ago in formulating the considerations for siting 



