526 



Costle 5. 



factors. However, the considerations above suggest that Santa 

 Barbara Basin would be a better area. Field Investigations 

 along these lines are recommended." (National Academy of Sciences 

 National Research Council "Disposal of Low-Level Radioactive Waste 

 Into Pacific Coastal Waters" (Publication 985 - 1962).) Marine 

 scientists today probably would not accept the Santa Barbara 

 Basin as a better alternative to the Santa Cruz site, but In the 

 event that field studies were conducted and seemed to demonstrate 

 the advantage of the alternative site, dumping «ould have occurred 

 In the Santa Barbara Basin. Does EPA have Information on this 

 possibility? Did the Academy or some other agency conduct field 

 studies? What are the Impacts of wastes on the basins and the 

 probabilities of escape of wastes from both basins into the 

 borderlands? 



5. Multiple sites exist at the Farallon Islands. What 

 are the possibilities of multiple radioactive dumpsites within 

 and outside the designated areas of the Channel region? 



6. Short-dumping needs Investigating. In difficult 

 weather, barges hauling radioactive wastes would dump their loads 

 in the open ocean short of the designated sites. This practice 

 of the 50 ' s and 60 ' s may still represent a problem today in the 

 control of other than radioactive wastes. A 1973 NOAA report 

 (Robert Brown and Edward Shenton, "Submersible Inspection of 

 Deep Ocean Waste Disposal Sites off Southern California," Plessejtr 

 Environmental System) noted "indication of poor dumping control" 

 indicated by "lack of debris" In the official dumpsite in the 



San Diego-Mexican waters. What evidence has been compiled on 

 dumping control , waste monitoring, short dumping and other 

 littering practices? References to EPA policy on dumping en- 

 forcement would be helpful . 



7. The EPA has not addressed the complexities of multiple 

 waste dumping at the various Identified radiological sites. The 

 NOAA-Plessey report (30) notes that investigators of the San Diego 

 site were surprised that the area was also a munitions dump. The 

 Farallon Island sites were also subject to multiple dumping if 

 such an inference from the Information Paper (1+) is accurate: 

 "...it was the only site (at the FarallonS )used exclusively for 

 dumping radioactive wastes." The Santa Cruz site is listed on 

 navigation charts as a U.S. Navy chemical and munitions dump. 

 l<rhat chemicals besides radiological wastes are dumped at this and 

 other Channel sites? Did the EPA 1972 moratorium against radio- 

 logical dumping apply to chemicals and munitions? Is the i^avy 

 obliged to observe this moratorium or has the Navy recognized the 

 EPA order? 



8. Public attention in California recently has focused 

 primarily on radiological dumping. To understand this issue, a 



