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biological or other grounds, by the competent inter- 

 national body in this field, at present the Inter- 

 national Atomic Energy Agency, as unsuitable for 

 dumping at sea. 



The Convention's definitions are contained in Article III. 

 The term "dumping" is defined, in relevant part, as follows: 



1. (a) "Dumping" means: 



(i) any deliberate disposal at sea of wastes 

 or other matter from vessels, axrcraft, platforms 

 or other man-made structures at sea: 



(b) "Dumping" does not include: 



(ii) placement of matter for a purpose other 

 than the mere disposal thereof, provided that such 

 placement is not contrary to the aims of this 

 Convention . ( Emphasis added • ) 



It is apparent that the Convention regulates deep seabed 

 emplacement of radioactive wastes if the wastes are defined 

 as "high-level" by the appropriate international body and if 

 enplacement constitutes "disposal at sea." This discussion 

 will assume that the wastes in question are "high-level." 

 On the second question, you have properly observed that the 

 phrase "at sea" could refer either to the location of the 

 disposing party, and thereby include disposal from a vessel 

 "at sea" by emplacement of wastes beneath the ocean floor, 

 or to the actual disposal into ocean waters, which would 

 include disposal down to -to but not below the seabed. The 

 Ismguage of the Convention does not resolve this ambiguity; 

 hence, it is not clear from the actual terms of th e Conve n- 

 tion whether control of s eabed em placement is included in 

 the parties' agreement . 



I have been advised that the issue has not been formally 

 discussed at meetings pursuant to the Convention and that 

 informal discussions suggest that the parties probably would 

 not agree on the interpretation of "at sea" in this context. 

 Several parties reportedly have stated that they would regard 

 deep seabed emplacement as a violation of the Convention, but 



