517 
-19- 
the validity of several of his principal conclusions were expressly 
acknowledged by EPA at the October 1980 hearings held in San 
oo ee 
The GAO Report also fails to mention a report compiled from 
EPA's survey of the Atlantic 3800 meter dumpsite, "Radionuclides 
at the U.S. Radioactive Waste Disposal Site in the Hudson Canyon," 
which showed significant levels of Americium-241 in the rattail 
fish, Coryphaenoides armatus, which the author concludes came 
from the radioactive eee Bf EPA calls this a speculative 
conclusion, saying that "[s]tudy of this data is continuing, and 
it appears that resolution of the open question will have to come 
from further baseline and dumpsite ae Regardless of 
EPA's "official" views on this study, at minimum, GAO should have 
cited that report and concurred with the EPA recommendation that 
further monitoring is needed. 
The GAO Report cites the 1971 National Academy of Sciences study 
"Radioactivity in the Marine Environment" as the most definitive 
work on "marine radioecology eu ae While that study is 
extensive and thorough, it deals primarily with radionuclides 
from "fallout," "run-off" and "“out-falls" from the operation of 
nuclear power plants; very little attention (two-three pages) is 
50/ 
specifically given to the ocean dumping program. Throughout the 
46/ See October 1980 Hearings, supra note 20, at 122-24, 129-32, 
and in particular, 148-49. 
47/ W.R. Schell & A. Nevissi, supra note 34. 
48/ November 1980 Hearings, supra note 6, at 373. 
49/ GAO Report, supra note 3, at 12. 
50/ National Academy of Sciences, Radioactivity in the Marine 
Vv 
ironment (1971). Pages 35-36 of that 258=pace recort focus on 
ckaged radioactive waste disposal. 
