498 



ity in the local fish. However, in 1977, the State of California's Health Department, 

 Radiological Health Section, detected Cesium 137 in samples taken from a Berkeley 

 local fish market. 



And in 1978, the EPA tests at the Farallons site confirmed the State of Califor- 

 nia's findings. According to a Lawrence Livermore Laboratories report of January 6, 

 1978 (Radionuclides in the Marine Environment Near the Farallons Islands, UCRL- 

 52381), approximately twice the amounts noted in the State of California tests were 

 found in Red Rock Cod caught near the Farallons Islands. Lawrence, formerly 

 known as Radiation rather than Livermore, incidentally, is one of the orginal 

 sources of the materials which were dumped at the site. The report, prepared under 

 contract with the U.S. Energy Research & Development Administration, has been 

 made public, but the EPA has not yet issued one. It is expected to basically 

 substantiate the LLL document. 



Essentially, the LLL report attributes the local contamination to global fallout 

 from the sixties, since tests from the Chicago fish markets have about the same 

 amounts of radioactivity. This is claimed, despite clear evidence in a previous EPA 

 report that Cesium and Plutonium in a core sample of the ocean floor contained 

 concentrations which "exceed the expected fallout range" (made to the Internation- 

 al Atomic Energy Agency, Vienna, March 1976, IAEA-SM-207/65). One explanation 

 is a "very low-level manifestation of transport or radioactive contamination from an 

 area other than at Station 13A . . . ." That the source may be from the 150 

 concrete blocks at the Farallons is suggested by an extensive discussion on page 10 

 and 11 of the same report, about Cesium 137 leaching from containers at the 

 Atlantic 2800 meter dumpsite. 



However, when an average person looks at the color photographs of the bottom- 

 feeding red fish next to a ruptured barrel filled with irradiated dead animals (EPA 

 Operations Report, ORP-75-1), no amount of "official explanation" will suffice to 

 dispel obvious concern about possible contamination in the food chain to humans. 

 This is especially so, since Cesium 137 is some "7-15 times greater" (in potential 

 hazard) "than from Strontium 90." It is absorbed through the stomach into the 

 blood stream, and then into the bone marrow where it causes leukemia — cancer of 

 the blood. (Appendix B contains copies of correspondence with the California State 

 Department of Health and of the documents referenced therein.) 



Finally, I and two other local scientists agree that the recent EPA tests at the 

 Farallons must be considered inadequate and superficial, since they did not 

 throughly monitor the local abalone, clams, oysters, and mussels, which are known 

 to bioconcentrate radioactivity by a factor of ten to one. In addition to local con- 

 sumption, oysters are grown commercially in Pt. Reyes Station, a nearby local 

 community in the heart of a National Seashore visited by thousands of tourists 

 annually. 



Meanwhile, increasing argumentation continues in scientific circles about the 

 potential dangers of accumulating even low-level radiation over time spans as long 

 as thirty years (Goffman, Sternglass, and others). The general concensus, however, 

 seems to be that no amount of radioactivity can be guaranteed safe because of its 

 uncertain effects on long-term genetics in plants, animals, and humans. Hence, the 

 cessation of ocean dumping by this country in the sixties based on the change in the 

 then Atomic Energy Commission (AEC) philosophy from dispersion to containment 

 in its disposal methods. 



Casting doubts on the overall effectiveness of the EPA's ability to monitor, under- 

 stand, or control risks to public health from radiation sources is a Government 

 Accounting Office report (described by the media as "scathing"), CED-78-27 of 

 January 20, 1978. While the DOE may call safety its primary criteria, the facts are 

 that "Of all EPA programs, radiation protection is the least funded" (from GAO 

 report. Digest). The bottom line of our Federal policy on radiation safety seems to be 

 "all talk and no money." 



ADDITIONAL OCEAN DUMPING 



Dissatisfaction with the EPA handling of the Farallons problem led me to suspect 

 the surveys had a primary purpose of preparation for consideration of renewed 

 ocean dumping by this country. Obviously, an existing low-level radiation dumpsite 

 cannot be admitted to be unsafe, if additional dumping of high-level waste is to have 

 any credibility. Also, it could lead to embarassing political conflict with Great 

 Britain, which is currently the largest source of continued ocean dumping of Euro- 

 pean low-level radioactive wastes. The total amount dumped by seven countries is 

 approximately three times the curies disposed of by the United States in the ocean 

 before we stopped doing it here in the nineteen-sixties. 



In fact, Mr. Robert S. Dyer, who was in charge of the Farallons surveys in 1977 

 and 1978, has said: "For certain classes of radioactive wastes, ocean dumping onto 

 the ocean floor, under carefully controlled conditions, may offer an environmentally 



