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facility for reprocessing irradiated reactor 

 fuels or irradiated fuel from nuclear power 

 reactors. 



In contrast with these domestic requirements, which we 

 believe should be adopted internationally, the international 

 reliance on a release rate approach opens the door to the 

 possibility that high-level radioactive wastes could be dumped, 

 as long as they meet quantitative requirements. Aside from the 

 absence of our domestic requirements, one central problem with 

 that approach is that the IAEA, and the proponents of higher 

 release rate levels, have not come forward with demonstrated 

 containment systems that control release rates in a quantifiable 

 manner. Until such containment systems are developed, we believe 

 that the definition of radioactive wastes unsuitable for dumping 

 should be based, at minimum, on dumping rate limits and the 

 initial specific activity of the wastes. Moreover, in order to 

 feasibly carry out any sea disposal based on release rates, a 

 program would have to be carefully developed which would require 

 uniform packaging designs for various classes and types of 

 wastes. Such packaging designs should be tested under both 

 simulated conditions and in situ to establish acceptable 

 standards of resistance to pressure, corrosion and leaching at 

 the required dumping depths. These same concerns have been 

 presented by the United States' delegation at past consultative 

 meetings under the Convention. 



Although U.S. officials have cited our isolation and 

 containment requirements as an example of the appropriate caution 

 and restraint that is needed, there does not appear to be a 



