570 
= 
defined and thus this distinction is not always clear. In any 
event, there is substantial evidence that the past U.S. dumping 
23/ 
program involved more than just low-risk waste, yet this 
possibility does not seem to enter into GAO's analysis. 
The GAO Report defines three classes of radioactive waste: 
24/ 
high-level; transuranic; and low-level. = These classes are, 
in effect, derived from the source of the waste product and thus 
do not give a quantitative or qualitative picture of the material's 
risk potential. Although the report does mention that low-level 
2157, 
waste can be "highly contaminated," by continually using the 
term low-level and claiming that deficiencies in the data have 
little impact on determining the environmental and health 
consequences, GAO gives the erroneous impression that past dump- 
ing involved only lower risk material. 
A more quantitative definition is given by the Atomic Eneray 
Cemmission in its 1955 report on Radioactive Waste Disposal 
23/ See Waste Dumping: Hearings Before the Subcommittee on 
Oceanography of the House Committee on Merchant Marine and 
Fisheries, 97th Cong., lst Sess. 97-20 (1981) at 388-91 (testi- 
mony of Michael Pogodzinski) [hereinafter cited as September 1981 
Hearings]; and M. Herz, "Some Like It Hot: Reactivating Waste 
Alternatives," Oceans, Vol. 15, No. 2 (1982), at 65. See also, 
infra notes 27-31 and accompanying text. 
9A 
<4 
"High-level wastes included (1) spent or 'used' reactor fuel 
Which will be classified as waste if not reprocessed and (2) the 
by-prcducts coming out of a reprocessing plant which cortain 
haghmhyatoxicy nuclear lssronspEOGdUGES il. uel 
"Transuranic waste results predominantly from reprocessina 
spent fuel and fabricating plutonium to produce nuclear weapons. 
These are man-made radioactive elements that, like high-level 
waste, have lives of thousands of years . . 
“Low-level nuclear waste is generally considered to be any 
radioactive waste that is not high-level or transuranic waste." 
(footnotes omitted.) GAO Report, supra note 3, i-2. 
25/ Wal. he Be. 
