593 
-35- 
As a final point on the utility of monitoring as a basis for 
setting future policy, the GAO reprimands the EPA for not having 
long ago incorporated Sietehatt cnet guidelines into EPA's domestic 
regulatory woven 07234 Since United States policy dating back to 
1970 has been not to use the ocean as a radioactive waste dump- 
site, the GAO's criticism rings hollow. Stated differently, 
the GAO focus on updating our existing regulations places the 
proverbial "cart before the note aia AESKe poe Kone e-WlIE Cope ay) 
above findings, the analysis of information that needs to be 
obtained from (1) past dumpsite and "test" site monitoring, (2) 
other U.S.-based ocean research and monitoring, and (3) partici- 
pation in international programs and activities, including IAEA 
advisory groups, NEA's Environmental Surveillance Program, and the 
International Seabed Working eu collectively must be viewed 
aS a prerequisite to any formal revision of this nation's regula- 
tory program concerning ocean dumping of radioactive wastes. 
Conclusion 
In conclusion, there are serious problems with the findings 
and recommendations of the GAO Report. The Report is permeated 
with inadequate documentation, misrepresentation of evidence, and 
failures to acknowledge the existence of other pertinent evidence. 
ae ChOMRepOTt,, Subma motel S) aate 22-23). 
94/ Heywood, John, “Proverbs,".(1546), Part II, Ch. 7. 
95y This latter program, chaired by the Department of Energy's 
Glenn Boyer, is the international complement to DOE's Seabed 
Disposal Program. See supra, note 14. 
