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                                                             U.S. EPA Headquarters Library
                                                                   Mail code 3201
                                                             1200 Pennsylvania Avenue NW
                                                                Washington DC 20460
                      FACT•SHEET ON OCEAN•DUMPING OF•RADIOACTIVE•WASTE MATERIALS
                                             Prepared For
                                       House of Representatives
                                      Subcommitte  on  Oceanography
                                                of the
                              Committee on Merchant Marine and Fisheries
                                    Environmental  Protection  Agency
                                     Office of Radiation Programs
                                            Washington  D.C.
                                                             \
                                           November  20,  1980
.  t

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                               INTRODUCTION
    Low-level radioactive wastes are routinely generated by a wide range
of military and non-military operations,  including'nuclear powerplant
operations, commercial manufacturing processes, and research and medical
institutions.  When we say low-level radioactive wastes, we generally
mean all those materials not directly resulting from the processing of
spent reactor fuel.  Low-level wastes defined in this way may be
hazardous, depending upon their concentration and their proximity to man
or other organisms.  The bulk of these low-level wastes are by-product
materials, especially materials such as equipment, tools, and lab
clothes which have become contaminated by exposure to or contact with
radioactive materials.  Some examples of by-products materials are
radioactive cobalt, strontium, americium, and cesium.  At times, they
also may include small quantities of "source materials", such as uranium
and thorium, or traces of "special nuclear materials" such as plutonium
or enriched uranium.

    From 1946 through 1970 the United States disposed of these
radioactive waste materials either by shallow land-burial at
goveripent-owrred sites, or by ocean dumping at AEC-approved sites.
Because the materials were potentially hazardous, they were given
special attention in transport and handling.  But because they were
regarded primarily as garbage,  precise records apparently were not kept
of the disposal operations.  Materials for land burial were packaged in
a wide variety of containers, while materials for ocean disposal were
encased primarily in concrete-filled steel drums.

    Today, the records of the ocean dumping activities consist primarily
of licenses issued by the Atomic Energy Commission to private
contractors and of logs indicating the approximate locations of disposal
sites.  In most of the cases the records do indicate the nature of the
materials, the quantities, the estimated radioactivity, and the
approximate coordinates of the dumping location; unfortunately, they do
not indicate the specific isotopic content, and neither the content of
the containers nor the precise dumping locations can be verified.
Records of military operations and government contractors (such as the
national laboratories) may also still exist, but are not currently
available.
                                                               3G4SO

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    The environmental survey work of the ocean nuclear waste dumpsites
by EPA was initiated under the mandate of the Marine Protection,
Research and Sanctuaries Act (PL 92-532) in order to provide a technical
basis for both the development of regulations and criteria and the
consideration of future disposal alternatives.  In 1974 EPA sent an
initial survey team to the Farallon Islands dumpsites to confirm the
feasibility of locating the containerized waste packages, and to
determine if any measurable amounts of radioactivity could been released
into the dumpsites.  Using an unmanned submersible vehicle several
cannisters were successfully located, underwater photographs were taken
to assess the condition of the drums, and sediment samples were
collected in proximity to both intact and imploded.drums.  Low levels of
Plutonium 238, 239, and 240 were detected.
                               *i'i
    In 1977, two additional surveys of the Farallon Island Sites were
undertaken; the first to provide estimates of biologic activity and
diversity, and to take samples of the water column and the ocean bottom,
and the second to measure ocean currents and attempt the recovery of one
of the waste cannisters.

    In the Atlantic Ocean a similar series of investigations was
undertaken at the 2800 and 3800 meter sites.  A preliminary sampling
team went out to the 2800 meter site in May, 1974; in 1975 three dives
in a submersjble vehicle were made at the 2800 meter site to locate and
document the condition of drums and take a variety of sediment, water,
and biological samples.  In 1976 similar data and a waste canister were
recovered from the 2800 meter site for detailed laboratory analysis of
canister corrosion and physical integrity, and in 1978, similar samples
were obtained from the 3800 meter site and a waste drum was recovered
for analysis.

    This Fact Sheet is a summary of information currently available to
EPA about these waste dumping activities.  It includes:

    1)   A history of dumping operations.

    2)   A tabular summary identifying all known sites, the types of
         materials dumped, the licensed dumping agents, and indicating
         whether or not EPA has surveyed the sites;

    3)   Summaries of the survey work which has been done under contract
         to EPA and in conjunction with EPA scientists;

    4)   A list of the principal statutory authorities relating to the
         ocean dumping of low-level radioactive materials;

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                       HISTORY OF DUMPING OPERATIONS
     On the basis of the information EPA has gathered to date, the
following are salient points in the history of U.S. ocean dumping of
radioactive materials.  A tabular summary of the designated dump sites
follows this list

     o  Between 1946 and 1970 the ocean dumping of radioactive wastes was
     conducted under the licensing authority and direction of the Atomic
     Energy Commission;

     o  In 1960, the AEC imposed a moratorium on the issuance of new
     dumping licenses, allowing existing licenses to remain in  orce and
     to be renewed;

     o  By 1963 most ocean dumping activities had been phased out, and,
     in 1970, the U.S. terminated all ocean dumping of radioactive waste
     materials;

     o  In 1973, the "U.S. ratified the 1972 London Dumping Convention,
     prohibiting, among other things, the ocean disposal of high level
     nuclear wastes and allowing for the future dumping of low-level
     radioactive wastes only under controlled conditions stipulated by
   j*the Convention;

     o  From 1946 thru 1962 (two years after the license moratorium), the
     U.S. dumped a total of approximately 89,400 containers with an
     estimated inventory of 94,400 curies (Ci) of radioactivity;

     o  Between 1963 and 1970 (when all dumping was terminated) the U.S.
     dumped only about 350 containers with an estimated total activity of
     about 230 curies.

     o  The Farallon Island Sites (collectively) received approximately
     99 percent of the radioactivity dumped in the Pacific Ocean;

     o  The Atlantic 2800 Meter Sites received approximately 96 percent
     of all radioactivity dumped in the Atlantic.

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    Notes to Table

If  In contracting and licensing the ocean dumping of radioactive
    wastes, the AEC designated general areas for approved dumping.  In
    some instances these areas were identified by single coordinates and
    the wastes were concentrated in relatively specific areas, while in
    other instances the AEC designated much broader areas .and allowed
    those dumping to proceed according to general guidelines.  Dumping
    under these designations resulted in much less concentrated dumping
    activities and a multitude of individual "dumpsites".  The number of
    such individual dumpsites under a particular heading in this column
    is indicated in parentheses.  The designation Al through A12, GM1
    and GM2, and PI through P13 refer to the NRC site numbering system.

21  Central coordinates designate dumping areas thought to have received
    concentrations of waste materials.  Actual coordinates may have
    varied over wider distances.

3/  Approximations for land references: an asterisk means that EPA has
    not plotted the coordinates on nautical charts to confirm the stated
    distance from land; blanks mean we haven't found the information yet.

4/  Three types of materials were dumped under AEC licenses or by AEC
    contractors: by-product materials (B), source materials (S), and
    special nuclear materials (SNM).  By-product materials refer to a
    wide variety of substances which were exposed to incidental
    radiation.  Source materials include uranium and thorium.  Special
    nuclear materials include plutonium, uranium-233, enriched
    uranium-233 or 235, and any other materials which the AEC may have
    determined to be special nuclear materials.

SJ  Radioactivity is given in estimated curies at the time of packaging.

6J  Waste materials were generally either packaged in special containers
    which were then placed in concrete-filled steel  drums, or mixed
    directly in concrete which was in turn placed in the steel drums.
                                    8

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7J  AEC       U.S. Atomic Energy Commission
    AMI       American Mail Lines
    ARC       Atlantic Refining Company
    CMDC      Coastwise Marine Disposal Corporation
    CR        Chevron Research
    FWS       U.S. Fish and Wildlife Service
    ISC       Isotope Specialty Company
    MP        Magnolia Petroleum
    MSTS      Military Sea Transport Service
    NEC       Nuclear Engineering Company
    NIH       U.S. National Institute of Health
    NRDL      U.S. Naval Radiation Development Laboratory
    OTC       Ocean Transport Company
    PN        Pneumodynamics
    SMO       Socono-Mobil Oil
    UG        University of Georgia
    UH        University of Hawaii

81  There were some AEC approved ocean dumping sites for which EPA has
    no records of dumping activities.  They are as follows.
ll/-
         Pacific-Ocean

         39*30'N; 125*40'W
         37'40'N; 124*50-'W
         36 00'N; 124*00'W
         34*30'N; 122'50'W
                                   At!antic-Ocean

                                   41*33'N; 65'30'W
                                   41^33'N; 65*33'W
                                   41 28-38'N; 65*28-45'W
                                   38 30'N; 72*00'W
                                   36 30'N; 74*13'W
                                   36,15'N; 76*35'W
                                   34 15'N; 76*35'W
Based on NRC memorandum of 8/14/80 additional dumpings appear
to have taken place in the 1960's and are being characterized
in ongoing records research.

Under the terms of the AML license, AML was authorized to dump
along the path of its shipping route beyond depths of 1,000
fathoms (1830 meters).

Report published by NOAA in April 1973, "Submersible-Inspection
of Deep -Ocean -Waste • Pi sposal -Sites -Off -Southern Cal ifomia"
describes survey of Santa Cruz Basin.
*/
See note number 3/, above.

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                      SUMMARY-OF EPA SURVEYS•OF PAST
                   DISPOSAL SITES FOR  RADIOACTIVE  WASTES
    A number of reports have been prepared for the Office of Radiation
Programs (ORP) of the EPA to describe surveys of the old ocean disposal
sites for radioactive materials.  These surveys have been generally
described in EPA Annual Reports to Congress, ORP Radiological Quality of
the Environment Reports, the EPA Journal and elsewhere.

    In 1974, an initial survey term was sent to the Farallon Islands
sites.  These teams used an unmanned submersible vehicle to locate waste
drums. The Atlantic 2800 meter depth site was similarly investigated in
conjunction with NOAA studies at Deep Water Dumpsite (OWD) 106.  This
was followed in 1976 by an EPA survey of the Atlantic site using the
manned submersible ALVIft.  In 1977 two additional surveys of the
Farallon Islands were undertaken to provide estimates of the biological
activity and diversity or the area, and to obtain a wide range of
samples.  In 1978, the ALVIN was again employed to investigate
conditions at the 3800 meter depth Atlantic radioactive waste disposal
site.

    Geologists, biologists, radiochemists, physical oceanographers and
oceanographic engineers from many universities and oceanographic
institutions participated in shipboard and onshore laboratory tasks in
connection with the EPA surveys.  Reports of this work have been
submitted to the Office of Radiation Programs in various stages of
completion and about 30 are currently on file with EPA.  All of these
reports have been provided to the House Government Operations Committee
Subcommittee on Environment, Energy, and Natural Resources, and to other
interested government officials.

    The reports are summarized below in two sets: those prepared in
conjunction with the Pacific Ocean site investigations, and those
prepared in conjunction with the Atlantic Ocean site investigations.
Five of the Atlantic reports and three of the Pacific (Farallon Islands)
reports are final and have been published; and the remaining reports are
in varying stages of completion by contractors or are undergoing
scientific review within and outside EPA.  The reader should be aware
that both data and interpretations presented by the contractor for the
reports still undergoing review may be either incomplete or subject to
misunderstanding, and do not necessarily represent conclusions of EPA at
this time.
                                     10

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                              At!antic-Ocean
    The following is a summary of seventeen research reports prepared
for EPA/ORP on the 1974, 1975, 1976, and 1978 surveys of the 2800 meter
and 3800 meter Atlantic dumpsites.  In some instances where researchers
were involved in investigations at both the Atlantic and Pacific Ocean
sites, there may be overlap between information reported in Atlantic and
Pacific Ocean reports.

    (1)  Dyer, Robert S., "Investigation of Radioactive Waste Disposal
         at Deepwater Dumpsite 106", in May 1974 Baseline•Investigation
         of Deepwater Bumpsite 106, NOAA Dumpsite Evaluation Report
         75-1, December 1975.

    This published report describes the purposes of sediment and
biological sample collection at the site and the manner in which
shipboard operations were conducted.  Recommendations for future work
are also included.

    (2)  EPA Eastern Environmental Radiation Facility (EERF)
         radioanalytical data, found in: Dyer, Robert S., "Environmental
         Surveys of Two Deepsea Radioactive Waste Disposal  Sites Using
         Submersibles", Management of Radioactive Wastes from the
         Nuclear Fuel Cycle, IAEA, Vienna, March 1976.
              •^
    Tn*fs published paper describes the early survey work at the 900
meter and 1700 meter sites in the Pacific and the 2800 meter site in the
Atlantic.  Radioactive waste containers were located for the first time,
with the use of submersibles.  Radioanalytical results by EERF for the
2800 meter site in the Atlantic are presented in Table IV.   Cesium-137
contamination was found in three sediment cores taken from near waste
containers.  It is believed to be the result of leaching from the
concrete matrix of the containers.  At the Farallon Islands, values for
Pu-239, 240 found in sediment samples taken from near some waste
containers exceeded expected values for this latitude and depth, as did
the ratio of Pu-238 to Pu-239, 240.  The plutonium distribution in the
sediment near some containers indicates that the release from the
containers could have occurred many years ago.

    (3)  Neiheisel, James, "Sediment Characteristics of the 2800 Meter
         Atlantic Nuclear Waste Disposal Site: Radionuclide Retention
         Potential", EPA Technical Note ORP/TAD-79-10, September 1979.

    This EPA published report characterizes the sediments from the 1974
2800 meter radioactive waste disposal site survey.  The chemical
analyses were performed on sediments which had been in storage.
                                     11

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    This geochemical work, particularly the effort on cation exchange
capacity, will contribute to understanding of the potential for
migration of radionuclides released  into the deep marine environment,
where radionuclide retention by the  sediments is anticipated.  The
origin of sediments at the site and  characteristics of sediment
deposition are also of interest; the report indicates the* source as the
continental shelf and the Hudson Canyon adjacent to the dumpsite.

    (4)  Bowen, Vaughan T., and Linda Graham, "1976 Site-Specific Survey
         of the Atlantic 2800 Meter  Deepwater Radioactive Waste
         Dumpsite: Radiochemistry",  May 1979.

    This report presents the data on levels of radioactivity found in
sediment cores obtained at the 2800  meter site adjacent to a radioactive
waste container and in various areas of the disposal site.  Cesium-137,
plutonium-239,240, and americium-241 in some sediment cores were found
to be above the expected range for weapons testing fallout in sediment
for this latitude and depth.  In addition, iron-55 and cobalt-60 were
also found in sediment cores and are believed to have originated from
the waste containers.

    (5)  Colombo, P., R.M. Nelson, Jr., and M.W. Kendig, "Analysis and
         Evaluation of a Radioactive Waste Package Retrieved from the
         Atlantic 2800 Meter Disposal Site," September 197.8.

    This published report presents the results of analyses performed by
Brookjiiaven National^Laboratory on the first radioactive waste container
recovered from a waste disposal site.  It was retrieved by EPA for the
purpose of container corrosion and matrix degradation analysis for the
2800 meter depth Atlantic radioactive waste disposal site.

    Analyses in the report indicate  that the container had withstood the
rigors of the deep ocean environment.  The authors estimate that a
minimum of 100 years in the deep ocean environment would be required
before the concrete waste form would lose its integrity.

    (6)  Dayal, R., S.A. Oakely, and I.W. Duedall, "Sediment Geochemical
         Studies of the 2800 Meter Atlantic Nuclear Waste Disposal
         Site", June'30, 1978.

    This report analyzes and discusses the physical and chemical
properties of the sediments collected at the 2800 meter site.   These
parameters influence the amount of binding of radionuclides to the
sediment.  Cs-137 and Cs-134 were found to have been released from a
radioactive waste container, but the sediments were determined to be an
effective barrier to migration.  It was found in this study that
bioturbation (the reworking of sediments by organisms) can actively
redistribute radionuclides vertically in the sediment column.   Pore
water migration, in comparision, was negligible.
                                    12

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    (7)  Dexter, Stephen C., "Cruise Report on R.V. Cape Henlopen 12/76,
         1976 Atlantic Radioactive Waste Dumpsite Survey".

    This report presents the various scientific operations which were
ongoing during the 1976 radioactive waste disposal site survey, where
the various sampling stations were located, and the manner in which
operations were undertaken.

    (8)  Dexter, Stephen C., "Materials for Containment of Low-Level
         Nuclear Waste in the Deep Ocean", August 1978.

    This generic report of deep ocean corrosion processes for steels and
concrete explains in easily understandable terms the mechanisms and
expected rates of corrosion.  The report concludes with recommendations
regarding improvement of the reliability of the containers potentially
used for future ocean disposal practices.

    (9)  Polloni, Pamela T., and Isabelle P. Williams, "Characterization
         of the Atlantic 2800 Meter Deepwater Radioactive Waste
         Dumpsite-Macro-Infaunal Analysis", August 1977.

    This report summarizes the findings of an investigation into
abundance, biomass and species composition of the benthic infaunal
community at the 2800 meter depth site.   Age structure was also
investigated.   The samples were collected as a part of the sediment
sampling program with the use of a Soutar box core.

    High specJes diversity was found.  Polychaetes, followed by
crustaceans, were the most abundant organisms.  No extraordinary
organisms or distribution of organisms were discovered.

    (10) Rawson, Martine Dreyfus, and William 8.F. Ryan, "Geologic
         Observation of Deepwater Radioactive Waste Dumpsite-106",
         EPA-520/9-78-001, June 1978.

    The bottom terrain of the 2800 meter radioactive waste disposal  site
was investigated by direct visual observation using the manned
submersible ALVIN.  It was found to be characterized by meandering
channels, with some boulders and rock outcroppings.  The report attempts
to interpret the geological history of the site, where major natural
disturbances appear to have occurred in the past.  The rate of
sedimentation at the site is estimated to be 5 cm per 1000 years.
Sediment deposition in addition to this, with potential to further bury
radioactive waste containers, could occur through future downslope
sediment slumping.
                                    13

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    (11) Reish, Donald J., "Survey of the Benthic Invertebrates
         Collected from the United States Radioactive Waste Disposal
         Site in the Atlantic and Pacific Oceans", June 1977.

    Taxonomic identification was made of the benthic infaunal organisms
at both the 1975 Farallon Islands west coast radioactive waste disposal
site and in 1976 at the 2800 meter Atlantic site.  This report describes
the infaunal populations collected from both coasts, and provides a
comparative analysis.

    The West coast typically constitutes a more productive infaunal
regime.  Polychaeates were the most abundant constituent on both coasts,
but the number and size of the east coast populations were much smaller
than the west coast, as expected.  The author concludes that a greater
opportunity for biological movement of radionuclides exists at the west
coast site location.

    (12) Carney, Robert $., "Report on the Invertebrate Megafauna
         Sampled by Trawling in the Atlantic 4000 meter Low-Level
         Radioactive Waste Disposal Site 1978", September 1979.

    Examination of the benthic population via ottertrawl showed that the
predominant megafaunal organisms at the 3800-meter radioactive waste
disposal site were brittle stars (ophiuroids) and hermit crabs
(pagurids).  This information is in accord with sampling data from other
reg.ioj»s of the N.W. Atlantic from similar depths.  It is believed that
the ophiuroids, as well as sea cucumbers (holothuroids) could contribute
to vertical bioturbation.  Pagurids and ophiuroids could transport
adsorbed nuclides laterally.

    Characterization of bottom fauna will assist in assessing potential
pathways for radionuclide transport from the deep ocean to man.

    (13) Dexter, Stephen C., "On Board Corrosion Analysis of a Recovered
         Nuclear Waste Container," Technical Note ORP/TAD-79-2, August
         1979.

    This published EPA report discusses a short-term corrosion analysis
of the exterior of the radioactive waste container retrieved from the
Atlantic 3800-meter radioactive waste disposal site.  The container
surface is described prior to subsequent detailed laboratory analysis.
Some suggestions for improvement of package design are also incorporated.

    Such information will be useful to EPA in determining packaging
criteria for sea disposal of low-level nuclear wastes.

    (14) Hanselman, David H.t and William 8. F. Ryan, "1978 Atantic 3800
         Meter Radioactive Waste Disposal Site Survey-Sedimentary,
         Micromorphologic and Geophysical Analyses", June 1979.
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    This report describes the geological and topographical regime at the
3800 meter radioactive waste disposal site.  The area was observed
directly through use of the manned submersible ALVIN, and was found to
be unstable, due to sediment slumping or avalanche activity.  The
containers might be buried by these activities in the future.  They also
might be moved around and thus be subject to damage mechanisms other
than corrosion.

    Such geological information is important in developing future site
selection criteria for,the ocean disposal option for low-level
radioactive materials.

    (15) Musick, John A., and Kenneth J. Sulak, "Characterization of the
         Demersal Fish Community of a Deep-Sea Radioactive Dump Site
         (Results of Cruise, EPA-7801, R. V. ADVANCE II, 21-27 June
         1978), May 1978.

    Bottom fish were collected through deep water trawling operations.
No differences were found between the fish assemblage at the radioactive
waste disposal site and other regions of similar depth.  The dominant
fish species was Coryphaenoides armatos, the rattail, a large mobile
species capable of long-dfstance migrations.

    This information on fish population abundance, biomass, diversity
and migratory patterns assists in evaluating potential transport of
nuclides from the site to man.

    fci6) Reis"h, Donald J., "Survey of the Benthic Invertebrates
         Collected from the United States Radioactive Waste Disposal
         Site-Atlantic Ocean 3800-Meter Location", November 1979.

    Infaunal populations were taxonomically identified.  As was the case
at the 2800 meter site, polychaetes were the most abundant group at the
3800 meter site.  Since they actively rework the sediment, the potential
for slow radionuclide movement through the sediment exists.  The
organisms collected at this site were also similar in their small size
to those obtained at the 2800 meter site; Atlantic specimens are
typically smaller than Pacific infauna.   Some mention is made in this
report of feeding patterns and potential food chain Jinks.

    While some new species and genera of polychaetes may have been
collected, no unusual or aberrant forms were noticed.

    (17) Schell, W.R., and A. Nevissi, "Radionuclides at the U.S.
         Radioactive Waste Disposal Site in the Hudson Canyon, 350 Km
         Off New York City", January 1980.
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    This report, in first submission format by the contractor, provides
radioanalytical data for the nuclides cesium-137, lead-210,
plutonium-238, plutonium-239 and 240, americium-241, and strontium-90 in
biological and sediment samples taken from the 3800 meter Atlantic
dumpsite in 1978.  The sediments tested did not show significant levels
of radioactivity.  Americium-241 was recorded in very high levels
(significant concentrations) in the rattail fish, Nezumia bairdi,
although not in other biological samples or in sediments obtained
adjacent to radioactive waste containers.  The americium in the fish was
in lower concentrations in the muscle, or edible, fraction of the fish.
The rattail is not a commercially harvested species in the United
States, and no commercial fishing occurs in the immediate vicinity of
the dumpsite.  No other nuclides were found in elevated concentration in
this or other biological samples.  The author concludes that the
observed americium-241 in the rattail fish came from the radioactive
wastes.  In EPA's judgement this is a speculative conclusion, and it
cannot be verified at this time.  Other possible explanations are
measurement error or bipconcentration by the rattail fish of fallout
from atmospheric weapons tests.  Study of this data is continuing, and
it appears that resolution of the open questions will have to come from
further baseline and dumpsite sampling.
           Independently•Pub!ished Reports by Survey Participant
    (*f)  Ito, Akihiko, "Surveys of Deepsea Radioactive Waste Disposal
         Sites by USEPA.

    This report, in Japanese, describes the participation of this
Japanese scientist in the EPA surveys of the Atlantic Ocean 2800 meter
disposal site.

    (2)  Schell, William R.,  "Radionuclides at the Deep Water Disposal
         Sites Located Near the Farallon Islands in the Pacific and at
         the Mouth of the Hudson Canyon in our Atlantic", Presented at
         the Second International Ocean Dumping Symposium, Woods Hole,
         Ma., 15-19 April 1980.

    In this report, Schell summarizes his work for EPA at the Atlantic
and the Pacific dumpsites (number 10 in the Pacific summary and number
17 in the Atlantic summary).

    (3)  Schell, W.R., and S. Sugai, "Radionuclides at the U.S.
         Radioactive Waste Disposal Site Near the Farallon Islands",
         Health Physics, Vol. 39., No. 3, pp 475-496.

    This report is a formal publication of the work conducted for EPA by
these researchers at the Farallon Islands dumpsites (number 10 in the
Pacific summary).
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                               Pacific Ocean
     The following is a summary of eleven research reports prepared for
EPA/ORP on the 1974, 1975, and 1977 surveys of the Farallon Islands
radioactive waste disposal sites.


     (1)  Dayal, R., I. W. Duedall, M. Fuhrmann, and M. G. Heaton,
          "Sediment and Water Column Properties of the Farallon Islands
          Radioactive Waste Dumpsites," September 1979.

     Dayal et al have analyzed the sediments collected at the site for
geochemical properties which might affect the behavior of radionuclides
in the marine environment.  Dayal found that the nuclides tend to adsorb
to the sediment rather than remaining suspended in the water column.

     This report is important in understanding the role of such
parameters as pore water diffusion and also bioturbation for nuclide
mobilization.  The sediments at the site are being characterized in order
to evaluate chemical interactions of radionuclides with the sediments and
to predict potential transport pathways for radioactivity in the oceans.

          Interstate Electronics Corporation," Operations Report - A
          Summary of the Farallon Islands 500 Fathom Radioactive Waste
          Disposal Site," U.S. Environmental Protection Agency, Technical
          Note ORP-75-1, December 1975.

     This previously published report has been circulated extensively; it
summarizes the operational aspects of EPA's early survey work at the
Farallon Islands.

     (3)  Interstate Electronics Corporation, "Operational Plan, Phase I,
          1977 Farallon Island Survey," IEC 446SP 550.

     This operational plan describes the logistics involved in the first
phase of our 1977 survey, during which we performed surface ship trawling
and coring operations for geochemical, radiochemical, and biological
analyses.  Participants are listed.

     (4)  Interstate Electronics Corporation, "Operational Plan, Phase
          II, 1977 Farallon Island Survey," IEC 446SP 551.

     The plan presents the logistical plans for the second phase of the
1977 Farallon Islands survey.   EPA used the Canadian manned submersible
PISCES VI to make bottom observations and to obtain sediment cores in
close proximity to radionuclide containers for subsequent radiochemical
and geochemical analyses.  Participants are listed.
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     (5)  LFE Environmental Analysis Laboratories, "Radiochemical
          Analysis of Samples from the 900 Meter Pacific Dumpsite,"
          September 1979.

     This report presents raw data, without interpretation, of
radioanalysis of sediment and biological samples.  It has undergone only
preliminary EPA review at present.

     The conclusions which we have drawn from the report are that the
radiation measured in the biota is in the range expected from fallout and
that the concentrations present do not represent a source of harm to
either man or the marine environment.  Concentrations of radioactivity in
fish collected in the vicinity of the Farallon Islands are within the
ranges occurring from atmospheric fallout.  Human consumption of such
fish would yield an annual estimated dose that is approximately 1,000
times lower than the dose from radioactive materials occurring normally
within the human body.

     (6)  Reish, Donald J., "Survey of the Benthic Invertebrates
          Collected from the United States Radioactive Waste Disposal
          Site Off the Farallon Islands, California," August 1978.

     The contractor taxonomically identifies infaunal and benthic
organisms collected at the site.  He reports no unusual findings in terms
of biomass or species present.  No aberrant forms were found.

     EPA is attempting to characterize the biological populations in the
site,»«rea.  We are interested in studying the role of benthic and
infaunal organisms in terms of the potential for bioturbation (reworking
of sediments which might enhance mobilization of radionuclides), and for
biological uptake for potential transport through marine food chains.

     (7)  Robison, Bruce H., "Cruise Report:  Farallon Islands Disposal
          Site Survey; Phase 1-25 August to 2 September 1977.

     Dr. Robison's report summarizes the operations of the 1977 site
survey and also provides useful suggestions for future survey work.
     (8)  Robison, Bruce H., "Midwater Trawling Summary:
          Islands Disposal Site Survey, 1977."
Farallon
     Midwater organisms, many of which may be highly migratory, could
provide a go-between food chain transfer mechanism between deep ocean and
near-surface waters.  This report identifies and describes the mid-water
populations found at the Farallons site.  As in Reish's report (06),
there were no unusual findings in terms of biomass or species present,
and no aberrant forms.  The sample size was insufficient to provide an
understanding of actual food chain pathways between bottom and mid-water
regions.
                                    18

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        (9)  Rego, Jennifer A.,  "Deep-Sea Echinoids  and Asteroids of the
             Northeastern Pacific:  An Aid in Selecting Candidate Species
             for Chromosomal Analysis-And~0bservations Concerning Three
             Species of Sea Stars Collected by the Velero IT,11 March 1980.

        A literature search was performed by Rego to predict which benthic
   invertebrates were most likely to be found in the vicinity of the
   Faralion Islands and which ones might prove suitable for future
   chromosome study.   The  second section of  the report  describes deep-sea
   starfish collected at the site in 1977.  Although a  baseline study to
'  determine capability of visualizing  size and  number  of  chromosomes was
   not possible  from  Rego's  technique,  interesting  information  concerning
   life  history  was obtained by laboratory examination.

        Our  office has  an  interest  in determining whether  a marine
  organism's response  to radiation can be detected via cytogenetic
  laboratory procedures.


        (10) Schell, W. R., and S. Sugai, "Radionuclides in Water, Sediment
            and Biological Samples Collected in August-October 1977 at  the
            Radioactive Waste Disposal  Site  Near the Farallon Islands,"
            July 1978.

       Dr.  Schell  reports  on his measurements of very low  levels of
 radioactivity  in sediments obtained at varying distances from radioactive
 waste  containers  and in  sediments and  biota from  the  surrounding
 vicinity.   Although his  radiological technique  for  plutonium  is less
 sensitive  than that of other  researchers, his estimation of the upper
 limifof plutonium  that could be  present is apparently consistent with
 the conclusion of no  radioactivity in excess of background.  There was no
 detection of plutonuim in the edible portion of any fish.  In the case of
 cesium, his results were easier to compare with existing literature and
 they are comparable to background radiation.

      (11)  Silver, Gary R., "A Taxonomic Review of the  Farallon Island
           Sponge Fragments,"  February  1979.

      Or. Silver,  an  hexactinellid sponge specialist, analyzed  samples  of
the  large  hexactinellid for taxonomic  purposes.  EPA first observed these
sponges growing on the radioactive waste containers  at the site  His
report  confirms that  this  sponge,  a new  species, is  indeed a typical
hexactinellid which  is  growing to  a normal hexactinellid  sponge size.  It
is not  an aberrant organism.

     EPA's  interest  in the sponge stems from curiosity concerning the
sponge's large holdfast and the potential impact it might have on
acceleration or deceleration of container corrosion.
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                           STATUTORY AUTHORITIES
     There are seven principal authorities relevant to the ocean disposal
of radioactive materials, to oceans research, and to monitoring and
surveillance of dumpsites:

     o    The-Atomic EnergyAct of 1946

          Under this Act the Atomic Energy Commission, (AEC) was given
     exclusive authority for all matters pertaining to atomic energy.
     Subsequent executive actions and Acts of Congress transferred those
     authorities to other Executive Agencies.

     o    Energy Reorganization Plan No;-3 of 1970

          Under the Energy Reorganization Plan of 1970, the Environmental
     Protection Agency (EPA) was established, and the authority to
     "establish generally applicable environmental standards for
     protection of the general environment from radioactive materials..."
     was transferred from^the AEC to EPA.

    •*r-   TherMarine Protection^ Research; and Sanctuaries Act•of 1973•

          This Act (PL 92-532), commonly referred to as the Oceans
     Dumping Act, authorized EPA to regulate ocean dumping. Furthermore,
     the Secretary of Commerce, in conjunction with the Administrator of
     EPA, was directed to "initiate a comprehensive and continuing
     program of monitoring and research regarding the effects of the
     dumping of material into ocean waters..."
     o    The-Energy Reorganization-Act of 1974

          Under the Energy Reorganization Act of 1974 the AEC was
     abolished and its regulatory authorities were conveyed to the newly
     created Nuclear Regulatory Commission (NRC) while its other
     responsibilities were transferred to the Department of Energy.
                                    20

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0    EPA Regulations and Criteria-for Ocean•Dumping

     On January 11, 1977, EPA issued regulations and criteria for
ocean dumping pursuant to PL 92-532 (40 CFR Parts 220 - 229).  These
regulations specify that:

1)   radioactive materials must be contained to prevent their
     dispersion into ocean waters, and

2)   the containment system must be designed to remain intact until
     the radioactive materials decay to innocuous levels.
o    The National Ocean Pollution-Research and•Development and
     Monitoring'Planning-Act of-T97g

     Under this Act (PL 95-273), the National Oceanic and
Atmospheric Adminsitration (NOAA) is directed to: 1) establish a
comprehensive 5-year plan for federal ocean pollution research and
development and monitoring programs; 2) carry out a comprehensive
program of ocean pollution monitoring, including radiation; and 3)
provide necessary data to support and provide for the conservation,
utilization, and development of ocean resources.

o    The•London•Dumpi ng•Convent ion

     Thfe Convention on the Prevention of Marine Pollution by dumping
o*''Wastes and Other Matter (London Dumping Convention) was convened
in 1972 to prevent pollution of the marine environment.  The
Convention was signed by the United States in December, 1972 and
ratified fay the U.S. Senate in August, 1973.  The Convention became
effective in August, 1975, and has since been ratified by about 40
nations.
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