461 



So based on what is known, given limited information, scientists 

 have drawn certain conclusions. Concerning certain pollutants, like 

 heavy metals, polychlorinated biphenyls or Kepone, scientists have 

 concluded that those pose very serious problems. They're problems 

 about which we know something — for example they are toxic to 

 human health and animals. They also pose problems in areas close 

 to the human population and to heavy concentrations of living 

 resources that are used by people. Therefore, scientists make their 

 judgment, and their judgment is limited to what we now know. 



Mr. Studds. On page 10 you state that research into the effects 

 of low-level waste dumping is needed not because of harm which 

 may have resulted from past dumping, but rather because we need 

 to prepare for requests for future dumping permits? 



Mr. Walsh. Yes, sir. And this gets to perhaps a difference in 

 philosophy between EPA and NOAA on the question of monitoring. 

 EPA's responsibility is regulatory. We look upon their monitoring 

 requirements to be those that are related to questions of regulation 

 and site-specific issues. 



Our view of monitoring is to go beyond that and to look into the 

 future as to what questions we haven't answered. In other words, if 

 you take a snapshot now of a nuclear dumpsite, for example, and 

 you test the sediments and test the animals, you'll draw certain 

 conclusions. 



What we're trying to do is push out the frontiers of fundamental 

 understanding so that the site-specific, regulatory monitoring will 

 mean something that we understand, so that we will focus on 

 problems that we haven't seen. The problems of PCB's sneaked up 

 on us; DDT did the same. We spend a lot of time looking at oil 

 pollution, but there are other problems coming down the road, 

 particularly the synergistic effects of all pollutants in the natural 

 environment. So what we in NOAA are trying to focus on in our 

 science, is what don't we know. 



We can look at these sites and draw conclusions, depending on 

 the exposure levels and the like, but what we're the most afraid of 

 is whether we're missing something when we're down there. Is 

 there some flaw in our understanding that leads us to conclude it's 

 not a problem? We want to do the research to be convinced of that. 



Mr. Studds. I understand. 



So to your knowledge, who is proposing the use of the ocean for 

 low-level waste disposal at the present time? 



Mr. Walsh. To my knowledge, there are countries in the world 

 that are still using dumpsites under the Ocean Dumping Conven- 

 tion 



Mr. Studds. I mean in our own country. 



Mr. Walsh. In our country? I would have to defer to EPA on 

 that issue. I think they mentioned the Navy. 



Mr. Studds. What I m getting at is we did ask them. 



Do you think the necessity or the possible necessity to move 

 beyond land-based disposal options is a political one or an environ- 

 mental one, inasmuch as a square foot of land seems to be repre- 

 sented by somebody in this institution as opposed to a square foot 

 of ocean? 



Mr. Walsh. On that question generally, going beyond just ra- 

 dionuclides, it is pretty clear that since 1970 we have had a philos- 



