576 
-18- 
drums out of the thousands that were dumped could constitute proof 
that the wastes portray no harm. Referring to the entire range 
of its dumpsite surveys, EPA's response was: 
it has been our technical judgment based on an under- 
standing of what materials were dumped and where they 
were dumped and how long ago they were dumped and our 
interpretation of the less than encyclopedic data that 
we have already collected, that there has been no harm 
from that past radioactive dumping. 42/ 
There are two important points in EPA's conclusion that GAO 
fails to take into account. First is the use of the past tense 
("there has been no harm") rather than the more positive statement 
GAO makes: "DUMPING POSES NEITHER AN ENVIRONMENTAL NOR A PUBLIC 
HEALTH HAZARD." 4¥ However, more significant to the analysis is 
the premise in the EPA statement that this technical judgment is 
based on an understanding of the nature, quantity, and age of 
Material dumped, when GAO's first conclusion states that this 
body of knowledge does not exist. 
It is interesting to note that the GAO report claims that 
although it sought opposing points of view within the scientific 
community on the question of hazard potential, it was only able to 
find one university professor (Dr. Davis) to provide counter evi- 
44 
dence, and this evidence they Seen eae Tale GAO dismisses 
Dr. Davis' opinions by summarily indicating that the conclusions 
of his report "were widely questioned by other scientists familiar 
45/ 
with the issue," the Report conveniently ignores the fact that 
42/ November 1980 Hearings, supra note 6, at 438 (testimony of 
Dr. Roger Mattson). 
43/ GAO Report, supra note 3, at 11 (emphasis in original). 
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