611 



-8- 



" a good monitoring program of previously used 



sites off the U.S. coastline is both necessary and 

 useful (1) to provide empirical data concerning 

 such matters as toxicity, transport, and critical 

 pathways, fates and effects of the radioactive 

 materials, (2) to assure the public that such past 

 dumping does not present any public health or 

 environmental hazards, and (3) to provide 

 scientific data which will contribute to 

 responsible policies and regulatory requirements 

 for the future; and 



° a good monitoring program of "test" sites off 



the U.S. coastline, unmodified by prior dumping 

 activities, is both necessary and useful (1) to 

 provide baseline data that will increase our 

 knowledge of the physical, geochemical and 

 biological processes of the marine environment and 

 routes back to man; and (2) to provide scientific 

 data which will contribute to responsibile policies 

 and regulatory requirements for the future. 



It is our view that those findings and conclusions still 



serve as constructive guidelines for further targeted research. 



The enactment of the domestic moratorium, the adoption of an 



international moratorium/scientific review (discussed in Part II 



below), and the findings contained in the 1982 monitoring report 



prepared for NOAA by the Rand Corporation, support the continuing 



validity of the conclusion contained in our 1982 critique, i.e., 



that: 



...at present it is premature to reverse the 

 existing U.S. policy of non-ocean dumping of 

 radioactive wastes. Unless and until a more 

 accurate assessment of the hazards of past 

 dumping has been completed, and unless and until 

 past dump sites and "test" sites have been 

 monitored in order to provide empirical data and 

 a sound predictive capability and validation 

 system, no serious consideration should be given 

 to the use of the oceans as a disposal medium for 

 radioactive wastes. 



