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CENTER 1751 M STREST NW WASHINGTON OC 20039 202 9720970 



FOR 



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■'-^■** ' Alan Houseman 



Diractof 



AND 



SOCIAL 



POLICY December 19, 1983 



Clifton E. Cunls 

 * J. Oavilt McAt0«r 

 Barbara M MUstetn 

 Paula Roberts 



The Honorable Norman D'Amours 



Chairman, House Subcommittee on Oceanography 



Committee on Merchant Marine and Fisheries 



House Annex 2, Room H2-541 



Washington, D.C. 20515 



Re: November 2, 1983 Oversight Hearing on 

 Ocean Disposal of Radioactive Wastes 



Dear Chairman D'Amours: 



By letter dated December 5, 1983, I submitted a written 

 response to a question that you addressed to me at the November 

 2, 1983 hearing before your Subcommittee. Following that 

 hearing, you forwarded to me five written follow-up questions 

 that were propounded by the Honorable Edwin Forsythe. This 

 letter addresses those questions and my responses. 



Question #1: One of the terms of reference to be defined by the 

 intersessional meeting of the London Dumping Conventioji is the 

 concept of burden of proof. You mentioned that the U.S. should 

 support the position that the prospective radioactive waste 

 dumpers be responsible for showing clearly that dumping is 

 safe. Noting the difficulty of proving a negative, what 

 documentation do you feel would prove that radioactive waste 

 dumping is safe? 



Answer: In my written and oral testimony at the November 2nd 

 hearing, I recommended that the Eighth Consultative Meeting of 

 the Contracting Parties should shift the "burden of proof" 

 requirements in relation to the international scientific review 

 of the risks associated with low-level radioactive waste 

 dumping. My testimony recommended "that prospective radioactive 

 waste dumpers come forward with authoritative evidence which 

 clearly shows that dumping is safe " (emphasis in original). To 

 date there have been very few studies which have assessed the 

 impacts of past dumping of radioactive wastes, either with 

 regards the dumping that occurred off U.S. coasts between 1946 

 and 1970, or the dumping in the OECD/NEA-sanctioned Northeast 

 Atlantic dumpsite. Targeted monitoring of those dumpsites would 

 provide valuable information to assist in determining the safety 

 of such activities. In the detailed comments that the 

 environmental coalition submitted to the Navy last June in 



