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criterion for determining a definition of high-level radioactive 

 waste which is unsuitable for dumping. 



The IAEA has recently announced that a technical experts 

 meeting will be held in Vienna on 28 November - 2 December 1983 

 to review and revise the IAEA's definition and recommendations 

 for radioactive matters under the Convention. Based on a review 

 of existing assumptions and models, revised release rate limits 

 will be considered. It is our understanding that the results of 

 that IAEA expert meeting will most likely be presented to a 

 subsequent IAEA advisory group meeting that will be scheduled for 

 October, 1984. 



Revisions of the definition of radioactive wastes are 



extremely important in relation to the continuing effectiveness 



of the London Dumping Convention. The use, internationally, of a 



release rate approach in defining high-level wastes is much less 



stringent than the requirements under our domestic law. The 



regulations which have been promulgated under our Ocean Dumping 



Act are premised on the concept of isolation and containment. 



They require that radioactive wastes be packaged or containerized 



to prevent escape into the marine environment until the material 



has radiodecayed to innocuous levels. 40 C.F.R. §227.11 (b) (1) . 



Moreover, rather than merely relying on a quantitative measure of 



maximum release rates in defining high-level wastes, our 



regulations qualitatively define high-level wastes as (40 C.F.R. 



§227.30): 



...the aqueous waste resulting from the operation 

 of the first cycle solvent extraction system, or 

 equivalent, and the concentrated waste from 

 subsequent extraction cycles, or equivalent, in a 



