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Twenty-two countries now participate in this NEA mechanism 

 and Japan is expected to join soon, now that it has ratified the 

 London Dumping Convention. The United States, as a member of 

 the NEA, participates in expert group meetings and, as a member 

 of the steering committee, reviews all activities relating to the 

 ocean disposal of radioactive material. 



In actual practice, few of the countries that are parties to the 

 London Dumping Convention or the NEA surveillance mechanism 

 engage in ocean dumping of radioactive materials. In 1980, only 

 four countries: the Netherlands, the United Kingdom, Belgium, 

 and Switzerland disposed of low-level radioactive wastes at sea. The 

 total radioactivity of materials dumped, however, is significant and 

 it increased this year. 



Protection of the entire marine environment requires that efforts 

 be pursued to improve the effectiveness of the ocean dumping 

 regime established under the London Dumping Convention. Our 

 concerns about the Convention's effectiveness center around three 

 issues: 



One, the adequacy of the IAEA definition and recommendations; 



Two, the need for more thorough research on the environmental 

 effects of ocean disposal of low-level radioactive wastes; and 



Three, the need for monitoring and assessment of the dumpsite 

 which is presently in use in the northeast Atlantic Ocean. 



With respect to the IAEA definition, let me expand on this a bit. 



In our judgment, the IAEA definition of high-level radioactive 

 material is incomplete and requires qualitative terms in addition to 

 the present quantitative limitations. Under the present definition, 

 no isotopes or particular types of waste are excluded from consider- 

 ation for at-sea disposal as long as their concentration is sufficient- 

 ly low. The U.S. position, reflected in the Marine Protection, Re- 

 search and Sanctuaries Act of 1972, is more specific about what 

 constitutes high-level waste. The act defines high-level waste as: 



The aqueous waste resulting from the operation of the final cycle solvent extrac- 

 tion system, or equivalent, and the concentrated waste from subsequent extraction 

 cycles, or equivalent, in a facility for reprocessing irradiated reactor fuels, or irradi- 

 ated fuel from nuclear power reactors. 



The U.S. definition precludes the dumping of certain substances 

 that are often considered to be among the most dangerous and 

 toxic. We are also concerned that the IAEA definition was based 

 upon assumptions that may be shown to be invalid as our knowl- 

 edge of marine ecology improves. 



On the question of the need for research and monitoring, we 

 have been frustrated in our attempts to better grapple with the 

 impacts of dumping by the lack of scientific evidence on critical 

 features of the marine environment and the effects upon it of 

 radioactive materials. There is an acute need for more information 

 on basic biological and physical processes. 



Moreover, we believe that a more thorough assessment of the 

 sites used for dumping radioactive materials, including the north- 

 east dumpsite, in the Atlantic must be undertaken, and a regular 

 monitoring program begun. In this regard, we are pleased to note 

 that the NEA has accelerated the development of a monitoring 

 program which is expected to come before its steering committee 



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