573 
-15- 
the report fails to consider the importance of that point in its 
eneilyede. Instead, GAO summarily equates low-level with low-risk, 
and in the process ignores intermediate wastes which generally are 
included in the "low-level" categorization. Some "low-level" 
radioactive Materials can be extremely hot or high-risk, and 
studies have shown that bioaccumulation and chronic exposure to 
such wastes can present serious risks to human health and/or the 
34/ 
Marine environment. 
Furthermore, the GAO Report refers to the “insignificant 
amounts of material that have been Lente while also empha- 
sizing that there is no complete catalogue of the information. 
The study states that there "is an overwhelming consensus among 
experts that even if the amounts of radioactive waste dumped in 
the past are significantly more than reported, they would not 
represent a hazard to people or to the ef AOE Sh To imply 
that it does not matter how much waste was dumped is an indefen- 
sible position, especially in this case where the specific type 
of nuclear material dumped is unknown and available records 
strongly suggest that some high-level and/or high-risk waste was 
dumped. 
If the volume of waste is irrelevant, then there would 
appear to be little reason for the GAO to conclude, as they did, 
that future dumpsites should be monitored. In addition, this GAO 
34/ See, e.g., Schell, U.R. and A. Nevissi, "Radionuclides at the 
U.S. Radioactive Disposal Site in the Hudson Canyon, January 1980, 
cited in November 1980 hearings, supra note 6, at 372-73; Impince- 
ment of Man on the Oceans, edited by Donald Hood, Riley Inter- 
SeleneSs (U7 pnGneiscaae” 27 jes S25—379 7 eiacl wellete, Si Guile; ReCGHO= 
active Contamination of the NEA Dumping Sites, IAEA-SM-248/111 (1981). 
a5/ GAO Report, supra note 3 at (iii). 
56/ sels eke Sill. 
