513 



Possibly the components of the radioactive waste of greatest concern at 

 the Farallon dumpsite are the long-lived alpha emitting radionuclides 

 whose total quantity is estimated to be about 30 Ci. Unfortunately we do 

 not have a nuclide by nuclide breakdown, but if we conservatively assume 

 the entire quantity is Plutonium-239, its toxicity index would be 

 106 m-^, a factor of 10,000 below that of the naturally occurring 

 radium in the seawater. Indeed, if the entire estimated waste inventory 

 of 14,000 Ci (alpha, beta and gamma) were Plutonium-239 (an absurdly 

 conservative assumption, given only to make the point) the waste would 

 still constitute a small hazard relative to the natural radioactivity. 



Further, it should be noted that the toxicity of the naturally occuring 

 radionuclides, large as it may seem, is orders of magnitude lower than 

 that of certain natural ly-occuring, non-radioactive toxic components of 

 sea water. Table 2 presents the Toxicity Index for several of these 

 non-radioactive toxic constituents, together with the Uranium and Radium 

 for comparison. Thus, the waste toxicity is insignificant in comparison 

 with the toxicity of the local natural radioactivity; and this, in turn, 

 is insignificant compared to the non-radioactive toxic material. (Also, 

 note that the toxicity of these non-radioactive materials will last 

 forever.) 



Table 2 



Toxicity Index of Sea Water Components in 



10,000 Km3 of Average Seawater 



Element 



Selenium 



Arsenic 



Lead 



Bar i um 



Mercury 



Silver 



Uranium 



Radium 



* Computed as the volume of water required to dilute inventory to EPA 

 drinking water standards. 



Given the above, it would seem that from a standpoint of potential hazard 

 (which should be the overriding consideration) it would make little 

 difference whether the estimated inventory of the radioactive waste were 

 "off" by a factor of 10 or even much more. 



.Some important points related to this analysis are: 



(a) Despite its predominance, one should not be concerned with the 

 biological effects of the natural radioactivity in that life has 

 evolved for billions of years in this environment and seems to have 

 adapted to it quite well. In fact, in previous millenia, levels of 



