555 
® a good monitoring program of previously used 
Sites off the U.S. coastline is both necessary 
and useful (1) to provide empirical data con- 
cerning 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 require- 
ments for the future; and 
@® a good monitoring program of "test" sites off the 
U.S. coastline, unmodified by prior dumping acti- 
vities, is both necessary and useful (1) to pro- 
vide 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 responsible policies and regulatory requirements 
for the future. 2 
In arriving at these findings, this paper addresses each 
of the GAO Report's principal findings and conclusions. Part I 
describes past and present U.S. policies and activities in 
relation to ocean dumping of radioactive wastes. It mentions 
briefly the statutory and regulatory framework that has 
developed, and notes the fact that since the issuance of a 
Council on Environmental Quality report in 1970 the United 
States policy has been not to use the oceans as a repository 
for radioactive wastes. It also references the reasons for 
EPA's current interest in the ocean option. It is in this 
context that the GAO Report -- to the extent it serves as 
support for a reversal of U.S. policy on this important issue -- 
requires rebuttal. 
Part II explains why there is a need for more complete 
information on past dumping practices. While complete and 
accurate data are not available, that does not negate the 
need for better information than now exists in order to 
(1) adequately assess actual or potential hazards from past 
U.S. dumping, and (2) formulate sound policies for the future. 
The GAO Report incorrectly assumes that all past dumping was 
low-level radioactive waste, that at most only low-risk waste 
remains, and that it presents low-risk to the marine environment 
and humans. As shown in this paper, evidence that high-level 
waste was dumped off our coastlines is in the public record. 
Similarly, evidence exists concerning the high-risk nature of 
some low-level radioactive wastes. Given that the specific 
