602 



behalf I am giving this testimony today, similarly supports that 

 moratorium. 



We do not feel such a moratorium prejudges the risk review. I 

 also can state that the issues raised by the Spanish resolution were 

 in hand well in advance of that February London Dumping Con- 

 vention meeting, so that the United States and other governments 

 had ample time to prepare for the fact that that resolution would 

 be presented if the proposed amendments were not accepted. 



One comment in this regard. Congressman Tallon asked an earli- 

 er question about whether or not the U.S.S.R. supported the mora- 

 torium resolution. The prior witness from the Department of State 

 misspoke in stating that the U.S.S.R. delegation voted against the 

 moratorium resolution. They did not vote against it, they ab- 

 stained, and I think that is a critical distinction. 



My prepared testimony describes the current situation, the de 

 facto moratorium that is in place. This is due, in part, to the Neth- 

 erlands Government having announced that it has found land- 

 based alternatives. It also is due to significant efforts by trade 

 union groups in the United Kingdom, Switzerland, and Belgium, to 

 boycott the handling and transport of radioactive materials slated 

 for sea disposal. I also indicate in my prepared statement that a 

 similar international resolution was adopted by trade unions in 

 Madrid, Spain, last week. 



At the eighth Consultative Meeting, participants will devote sig- 

 nificant attention to the terms of reference for the subsequent in- 

 tersessional scientific experts meeting. In that regard, we share the 

 concerns expressed by Chairman D'Amours and Delegate Sunia, be- 

 lieving that the parties should adopt a burden of proof standard 

 which requires prospective dumpers to come forward with authori- 

 tative evidence which clearly shows that dumping is safe. 



Second, in earlier testimony this morning, the legality of seabed 

 disposal under the London Dumping Convention was mentioned in 

 the context of the current London Dumping Convention review of 

 that issue. 



In my role as counsel to Greenpeace International, I will partici- 

 pate in the mid-December intersessional legal experts meeting that 

 will address this question. Greenpeace believes that seabed disposal 

 of HLW is covered by the Convention, and therefore prohibited, 

 since it is listed as an annex 1 substance. Reasons for that position 

 are summarily stated in my prepared testimony. The environmen- 

 tal coalition supports that position, and it is our hope that the 

 evolving U.S. position will reach a similar conclusion. 



Third, another LDC matter involves the IAEA's work concerning 

 revisions to the definition of HLW and the de minimus concept. 



As the IAEA review goes forward, it is our hope that U.S. Gov- 

 ernment officials will press for the adoption of existing U.S. re- 

 quirements, including those dealing with our isolation and contain- 

 ment concept and the qualitative definition of high-level radioac- 

 tive waste, both of which are more stringent than the international 

 requirements. 



Fourth, the State Department witness, in earlier testimony, men- 

 tioned the U.S. participation in the development of a South Pacific 

 Regional Seas Convention. 



