522 



SCENIC SHORELINE PRESERVATION CONFERENCE, INC. 



1+623 More Mesa Dr. 

 Santa Barbara, CA 93110 

 (805) 96!+-2U92 



October 3, 1980 



Honorable Douglas Costle 

 Environmental Protection Agency 

 1+01 "M" Street S.W. 

 Washington, D. C. 20U60 



Dear Secretary Costle: 



Scenic Shoreline is a party to evidentiary hearings on 

 the disposal of drill muds and cuttings at Lease Sale US tracts. 

 Ocean dumping generally, however, is a prime interest. Recent 

 publicity on radionuclide disposal at the Farallon Islands 

 reminds us that similar dumping has occurred in the vicinity of 

 the Channel Islands National Park and Marine Sanctuary. We seek 

 information from your agency on this channel dumping and request 

 specific EPA studies of disposal procedure and the impact of 

 dumping upon the marine environment and on food chains reaching 

 man. 



The Committee to Bridge the Gap has documented more than 

 forty-three ocean dump sites .( "Table of h^ Former Ocean Dump- 

 sites for Nuclear Wastes," August 19, I98O -- the Committee 

 indicates five more have been identified). EPA is concentrating 

 its research on four sites, two in the Atlantic and two at the 

 Farallon Islands on grounds that 90 "S of low-level waste containers 

 were dumped at these four sites. We request extension of the 

 studies to include the channel because of the particular ecological 

 sensitivity of this area, the cumulative stress upon this channel 

 marine environment of a number of resource exploitive activities, 

 the difficulty of extrapolating data from the Atlantic and the 

 Farallons to the channel, the special circumstances of disposal 

 under Navy auspices here, and other crucial factors. 



Your recent Fact Sheet ("Radioactive Waste Dumping off the 

 Coast of California," EPA, Office of Radiation Programs, August 15, 

 1980) fails to offer sufficient assurance that intensive research 

 of past disposal practices will be undertaken to highlight the 

 need for the necessary vast improvements in waste disposal in 

 line with new legislative directives on ocean dumping. 



a. The Fact Sheet notes (6) that EPA has sixteen reports 

 on the 1977 surveys of the Farallon Islands dumping that will be 

 published in April 1981. There, is no indication of studies of 

 other disposal areas suoh as the Channel. 



