539 



however, IAEA took formal note of the possibility of such disposal, and 



made a preliminary recommendation that it be excluded from the terms of 



6 

 the Convention. For the past several years, a number of U.S. agencies, 



both public and public-supported, have investigated the technical aspects 



of sub-seabed disposal. Some legal and political analysis has also been 



carried out, notably by Deese. The issue was aired at Congressional 



hearings in 1976 and 1978, and the Department of State, EPA, and ERDA 



9 

 presented legeil positions at the earlier hearings. A working group on 



sub-seabed emplacement has also been formed as an informal subgroup of the 

 Nuclear Energy Agency (NEA) . Lately additional legal opinions have been 

 produced by the National Oceanic and Atmospheric Administration (NOAA) and 

 by the Environmental Protection Agency (EPA) . Although other aspects 

 of the Ocean Dumping Convention may be problemmatic in relation to sub- 

 seabed disposal, the legal discussion thus far has centered on whether 

 sub-seabed disposal would constitute "dumping" within the terras of the 

 Convention. 



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