ny I have set forth the statutory bases that apply to low-level 

 radioactive waste dumping under both the London Dumping Con- 

 vention and the Ocean Dumping Act. 



I would like to very briefly address a few concerns in this area. 



EPA is currently developing regulations for issuance of low-level 

 dumping permits and expects that site selection, packaging criteria 

 and monitoring regulations will be completed by 1985. Bob Dyer 

 and Roger Mattson of EPA went into this in more detail so I won't 

 repeat or go into what is contained in my prepared testimony. 



Internationally, the United States, under EPA's leadership, has 

 been an active participant in the consultative and intersessional 

 meetings of the London Dumping Convention, and it continues to 

 be a major force addressing environmental concerns. Through U.S. 

 efforts, several provisos in the LDC have been written into law and 

 agreed to by the contracting parties, provisions that would not 

 have been there but for the U.S. efforts. 



The United States also participates in an NEA-sponsored pro- 

 gram for overseeing the dumping of low-level wastes in the North- 

 east Atlantic by certain European nations, and I believe was one of 

 the leaders in suggesting and encouraging that a detailed monitor- 

 ing program be created by the spring of 1981. 



One concern that the public interest groups have with respect to 

 low-level wastes is in the international area. We believe it is vital 

 that the United States continue to take an active part in meetings 

 and conferences, and in the development of multinational policies 

 and procedures. There are a variety of areas that we set forth in 

 the prepared testimony, concerns dealing with the IAEA and with 

 the NEA, issues that we believe are important and require the 

 attention of the various U.S. agencies. 



One issue that I did not mention in my prepared testimony that I 

 would like to cite is the possible area for addressing what is an 

 international concern, in the area of nuclear exports. I have repre- 

 sented some environmental groups in the last several months con- 

 cerning the expert of nuclear facilities to the Philippines. I think, 

 in looking at the issue of compliance with a mechanism like the 

 London Dumping Convention it might be that the United States 

 could require of potential exporters of nuclear technology that the 

 recipient nation be a signatory to the London Dumping Convention 

 in order to be allowed to receive the technology that the United 

 States has. It might be a way of at least raising the standard to a 

 minimal level as set forth under the London Dumping Convention. 



Domestically, we believe that the policy regarding ocean dump- 

 ing needs further clarification. Again in my prepared testimony I 

 have cited a letter from EPA Administrator Doug Costle that just 

 went out this past week to the Governor of the Northern Mariana 

 Islands, in which I think appropriately Doug Costle stated that: 



Until we have a better understanding of the possible impacts of low-level radioac- 

 tive waste disposal in the ocean, the United States will not encourage other nations 

 to ocean dump. 



However, as some of your questions earlier today, Chairman 

 Studds, have indicated, EPA's present efforts to develop permit 

 criteria lead to the impression that the United States may resume 

 dumping. Prior to EPA's compliance with its proposed permit regu- 

 lations schedule, a U.S. policy decision, made not just by EPA but 



