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ed. The current revised definition of such materials was adopted by the Fourth 

 Consultative Meeting of the Convention Parties in 1979. It is a definition based upon 

 radioactivity per unit mass of packaged material. For the dumping of low level 

 radioactive wastes that is permitted under the Convention there is also an extab- 

 lished limit on the total mass of radioactive materials which may be dumped 

 annually at a site and recommended total quantities which may be dumped at each 

 site. There is no limit on the number of sites, although site proliferation has been 

 discouraged. 



The IAEA is also responsible for providing recommendations to Parties on prac- 

 tices for dumping low level radioactive wastes. These include guidelines on environ- 

 mental evaluation of dumping applications, dumpsite selection, monitoring, assess- 

 ment, packaging of materials, and recordkeeping. 



The Definition and Recommendations are under continuous review. As part of 

 this effort, several activities are underway, including: 



(a) a review of the oceanographic model used in formulating the Definition; 



(b) a review of de minimis levels, to establish criteria for considering materials to 

 be non-radioactive for ocean dumping purposes; 



(c) initiation of a coordinated research program on transuranic cycling in the 

 marine environment. 



The IAEA is committed to continuing its responsibilities under the the London 

 Dumping Convention and other conventions. The U.S. strongly supports this role. 



Another international agreement concerning the regulation of ocean disposal of 

 radioactive materials is the Multilateral Consultation and Surveillance Mechanism 

 functioning within the Nuclear Energy Agency (NEA) of the Organization for Eco- 

 nomic Cooperation and Development (OECD). 



Established in 1977, this mechanism is charged with setting and reviewing guide- 

 lines, standards, and procedures for the safe disposal of radioactive material at sea. 

 NEA guidelines, which are to take into account the standards of the London 

 Dumping Convention and the IAEA's Definition and Recommendations, cover dump 

 sites and packaging and operating procedures relating to sea disposal. They also call 

 for assessment and review of environmental, ecological and radiological protection 

 studies relating to sea disposal activities, and require periodic assessments — at no 

 less than 5 year intervals — of the continued suitability of the selected dump sites. 

 Participating countries that decide to carry out dumping operations must notify the 

 NEA six months before the scheduled date of the operation (twelve months if a new 

 site is proposed). They must include in the notification the composition and charac- 

 teristics of the material, the site and reasons for its selection (including an environ- 

 mental assessment) and the procedures to be followed. These latter must be in 

 accord with NEA standards and recommended practices. In addition, the country of 

 origin must name, or request the appointment of, an Escorting Officer to ensure 

 compliance. The NEA reviews the proposed plans, if necessary seeking the views of 

 outside specialists, and names an NEA representative to observe the operation. The 

 NEA maintains records of disposal operations which, with the approval of the 

 country involved, may be furnished to the Inter-governmental Maritime Consulta- 

 tive organization (IMCO). 



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 

 U.S., 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 Mechanism engage in ocean dumping of radioactive materi- 

 als. In 1980, only 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. 



Adequate protection of the entire marine environment requires that efforts be 

 pursued to increase the effectiveness of the ocean dumping regime established 

 under the London Dumping Convention. Our concerns about the Convention's effec- 

 tiveness center around several issues: 



(1) the adequacy of the IAEA Definition and Recommendations; 



(2) the need for more thorough research on the environmental effects of ocean 

 disposal of low-level radioactive waste; and 



(3) the urgent need, in our view, for monitoring and assessment of the dump site 

 which is presently in use in the northeast Atlantic Ocean. 



