524 



Costle 3. 



obtained from these two primary U.S. Pacific dumpsites is by no 

 means complete." 



The summary of the October 18-27, 1977 surveys (Infor- 

 mation Paper, 22) offers this qualification: "While we have 

 presented here some observations from our surveys, extrapolation 

 of this information to general oceanographic predictors is pre- 

 mature. We can only encourage continued examination of these 

 and other sites through both U.S. and international efforts in 

 an attempt to determine that no as-yet-unidentified deep-sea 

 process could occur which would subject man and the .marine 

 environment to undue health risks from the sea disposal of low- 

 level nuclear waste." 



g. The Fact Sheet indicates (6) that EPA has not issued 

 any permits for ocean dumping of low-level radioactive wastes 

 allowable under the Marine Protection, Research and Sanctuaries 

 Act of 1972. The Fact Sheet states that EPA studies underway 

 "for determining whether such dumping should be allowed and where" 

 is scheduled to be completed by late 19^5. Scenic Shoreline here- 

 in requests additional information on these studies . 



h. "EPA and NOAA", according to the Fact Sheet (2)^ "are 

 currently preparing an interagency agreement to coordinate 

 oceanographic activities for evaluating ocean dumping as an 

 option for future disposal of low-level radioactive waste." 

 Is a draft agreement available? ^\fhat are the opportunities for 

 public input during deliberations on the agreementT 



i. The Fact Sheet refers to EPA regulations and criteria 

 for ocean dumping issued January 11, 1977 (l): "These regulations 

 specify that: 



"1. Radioactive materials must be contained to 

 prevent their dispersion into ocean waters, and 



"2. The containment system must remain intact 

 until the radioactive materials decay to innocuous levels." 



The definition of "innocuous levels" in any meaningful 

 context would require that ocean dumping not be permitted. 

 Further information on these legal terms would be helpful in 

 our studies. 



In somewhat greater detail we would like to define our 

 findings and concerns with respect t6 the Santa Barbara Channel 

 area dumping program, not only radionuclide disposal but other 

 chemical dumping and munitions disposal as well . 



1. Your Fact Sheet and other sources refer to the Santa 

 Cruz Basin site (33' 39' N, 119* 28' W) , some 33 miles southeast 

 of Santa Cruz Island. Between 1953-61 approximately 3,100 

 55 gallon drums of low level Radiation wastes were jettisoned in 



