523 



Costle 2. 



b. The list of Pacific Coast dumpsites (^) fails to 

 include one and possibly two sites in the Channel region in 

 addition to the one (Santa Cruz Basin) you list (See belowj. 



c. Appended to the incomplete list of West Coast sites 

 is the note (5): "Dumping sites were designated and licensed by 

 the Atomic Energy Commission and data on sites, containers and 

 radioactivity would now be withf.the Nuclear Regulatory Commission, 

 if the records still exist." This AEC-NRC information presumably 

 is now within the hands of EPA as a basis for its research on 

 agency regulatory plans. Scenic Shoreline requests this data . 



We also request an investigation on the reasons for destruction 

 of records if in fact they are non-existent . 



d. A further note (5) qualifies the curie count: 

 "Radioactivity at time of dumping. Much of this would be gone 

 now by normal radioactive decay." The long-lived radionuclides 

 (Plutonium 238, 239, 2I+O , Cesium 137) however, would not be 

 dissipated for millenia. 



e. The Fact Sheet claims (6) that fish caught near the 

 Farallon dumpslte are safe to eat with no measurable radioactivity 

 in edible portions and traces of Cesium 137 in the stomach and 

 skin comparable to amounts found in fish worldwide receiving fall- 

 out from nuclear tests. 



The "Information Paper -- Farallon Islands Radioactive 

 Waste Dumpslte Surveys 197^-1977" (R.S. Dyer, Office of Radiation 

 Programs, EPA), however, presents evidence of only minimal in- 

 vestigation of radioactivity In edible fish. The Fact Sheet con- 

 clusion appears to be based on the analysis of but a single 

 sablefish specimen ( Anoplopoma fimbria") , the one commercial fish 

 sampled according to the Information Paper (13)), hardly the 

 basis for valid generalization about food chains reaching man. 

 And, furthermore, the Information Paper (1^+) refers to the 

 "biological abundance and diversity" of the dump site studies as 

 a reason for excluding the area from further dumping "in order 

 to minimize any possible incidental' human uptake of particulate 

 radioactivity released into the site." This latter staitement, 

 however equivocal, does not warrant EPA assurance that commercial 

 fish are safe. 



f. The Fact Sheet, nonetheless, states (6) "Our evaluation 

 of the scientific inf ormation. , . ( f rom the Farallon studies)... 

 indicates no evidence of any harm to either man or the marine 

 environment." This misleading statement is accurate only if 

 taken literally -- there is insufficient evidence available. 



The Information Paper (15) confirms this appraisal: "More data 

 are needed on baseline levels of radionuclides in a geographical 

 area around a dumpslte if meaningful estimates are to be made of 

 gradual buildup and movement of any radioactive materials released 

 from the dumpslte." The Paper continues (22): "The information 



69-848 0-81-34 



