506 
types of nuclear material are unknown and that available records 
indicate that some high-level and/or high-risk waste was dumped, 
it is an unsound and risky leap of faith for GAO to conclude that 
we need not be concerned about what was dumped. 
Part III describes technical studies, testimony in public 
hearings, workshop findings and recommendations, and interna- 
tional criteria, guidelines and programs to show that U.S. 
efforts to date have not provided effective assurances that past 
dumping poses no hazards to the marine environment or humans. 
The limited surveys and studies that have been previously under- 
taken with respect to past U.S. dumping are not sufficiently 
conclusive to lay such an important concern to rest. Additional 
targeted research and monitoring, which will test the validity 
of present preliminary assumptions, is necessary if our govern- 
ment is committed to providing assurances of safety. 
Part IV describes the various domestic and international 
evidence which show that both past dumpsites and "test" sites 
off the U.S. coastline can provide useful and important infor- 
Mation as the United States formulates responsible policies 
for the future regarding ocean dumping of radioactive waste. 
The GAO Report urges the EPA to rely on international guidance 
as the basis for future policy decisions. Both Parts III and 
IV show that while the U.S. can benefit from lessons learned 
internationally, such guidance is no substitute for research 
and monitoring that is focused on past dumpsites and "test" 
sites off our coasts. The Report also reprimands EPA for not 
having revised already its ocean dumping regulations to incor- 
porate international guidance. Since U.S. policy dating back 
to 1970 has been not to use the ocean as a radioactive waste 
dumpsite, GAO's criticism rings hollow. More importantly, such 
a recommendation places the "cart before the horse." Given all 
the findings set forth in this paper, analysis of information 
gathered from monitoring past dumpsites and "test" sites -- as 
well as of information resulting from other domestic and inter- 
national ocean research and monitoring activities -- must be 
viewed as a prerequisite to any formal revision of this nation's 
regulatory program in relation to the ocean option. 
