479 



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arrangements could be set forth in a memorandiun of understanding 

 ("MOU"), as was suggested by Congressmen McCloskey and Moffett 

 at the Farallon Islands hearings. Such an MOU should also 

 require monitoring of specific sites. Absent an adequate MOU, 

 monitoring should be statutorily required. 



Having reviewed the evidence presented at last month's 

 Farallon Islands hearings, we believe that the most appropriate 

 course of action would be to undertake an in-depth investigation 

 of a few selected dumpsites (e.g., the Farallon Islands, Santa 

 Barbara and Massachusetts Bay areas) . Sites should be chosen 

 which, according to available records, seem to contain the most 

 sxibstantial and toxic quantities of radioactive material. 

 Evidence of significant potential for harm to man or the marine 

 environment at these sites would trigger broader review, that is, 

 a survey of all additional dumpsites. 



As a final recommendation, the public interest organizations 

 believe that the current Ocean Dumping Coordinating Committee 

 and the Ocean Diomping Advisory Committee, which address inter- 

 national and domestic concerns respectively, need to be 

 strengthened. One point the Farallon Islands hearings made 

 painfully apparent was the effect that lack of coordination 

 and reluctance to take on responsibility by and among federal 

 agencies have had in creating delays and in contributing to 

 public concerns. As in the case of the proposed advisory 

 committee on high-level waste disposal, both low-level 

 advisory committees should include all affected administra- 

 tive agencies (essentially the same as for high-level 



