525 



Costle 



k. 



a five by five mile or nine by nine mile area. In 1957. I960, 

 and 1972 the dump area was evidently monitored. We would 

 appreciate ac cess to these monitor reports . 



2. The 3,100 drums at Santa Cruz dump contained IO8 curies 

 of radioactive material. A similar number of barrels at one of 

 the Farallon sites contained 1,100 curies. (The curie count at 

 San Diego seems low as well, '+,^15 packages containing 33.6 

 curies. ) Unquestionably the records for these dumpsites are 

 fragmentary. Additional information is useful on the accuracy 



of the records on the radioactivity of these wastes . 



There is also no sufficient reason to believe that the 

 number of drums alleged to have been dumped represents a valid 

 statistic. In correspondence with Committee to Bridge the Gap, 

 an EPA official notes: "...there are gaps in the data, or 

 sometimes conflicting data concerning locations and curie amounts 

 of the wastes. As much as 10'^ error in estimate in curie amounts 

 should not be unexpected; effort at the time of the dumping was 

 not put into extremely accurate measurement and recording of 

 wastes, as they were seen as just that -- something to throw 

 away. In addition, many existing records, estimates though they 

 were, were periodically destroyed with other file records as they 

 attained twenty-five years of age." This appraisal is confirmed 

 by AEC documents. There is reason to believe that the records 

 could be off by considerably more than a factor of 10. For this 

 and other reasons each of the radionuclide disposal sites should 

 be investigated. \irhat plans does EPA have for thorough investi - 

 gations of each specific disposal site in the nation's waters? 



3. Little information is available on a second site in 

 the Channel region (3^* 30' N, 122* 50' W) , IO6 miles west of 

 Point Arguello. The Fact Sheet fails to mention this site which 

 is referenced in "Industrial Radioactive Waste Disposal Hearings" 

 before the Special Subcommittee on Radioactive Wastes, JCAE 

 (86th Congress), p. 2683. Any available data and references on 

 this site would be helpful in our research . 



U. Possibly a third site exists in the Channel. A 

 National Academy of Sciences report (71 ) observes: "Santa Barbara 

 Basin appears to be a better place for dumping than Santa Cruz 

 Basin, owing to its softer bottom (barrels sink deeper), faster 

 rate of deposition (burial in about 50 years), low oxygen content 

 (probably little rusting of barrels), and absence of minor amount 

 of benthos (no boring of concrete, mixing of sediment nor transport 

 by migration). Probable avenues of escape of wastes of both 

 basins are to the west, but reentrance into the borderland is 

 perhaps less likely for the Santa Barbara Basin than for Santa 

 Cruz. Apparently Santa Cruz Ba-sln was chosen merely because it 

 is the deepest close basin, without any regard for oceanographic 



